Sprague v Sprague - Settlement Agreement Enforcement

Iowa Supreme Court

Filed April 3rd, 2026

Detected April 3rd, 2026

Summary

The Iowa Supreme Court reversed the Court of Appeals decision in Sprague v Sprague, a marital dissolution case involving settlement agreement enforcement. The court reversed and remanded for ancillary trial on whether the parties reached a binding settlement, finding the district court's enforcement order unsupported by substantial evidence due to lack of an evidentiary record from the settlement conference. Lanora Sprague's request for appellate attorney fees was denied.

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What changed

The Iowa Supreme Court reversed the Court of Appeals decision in Case No. 24-1015 involving Johnathon and Lanora Sprague. The dispute concerned whether a settlement agreement should be enforced when the version drafted by Lanora omitted terms allegedly orally agreed to during an informal settlement conference regarding children's transportation and extracurricular activities. The Court found no record of the settlement conference proceedings, no transcript, and no evidentiary record from the hearing on Lanora's motion to enforce—leaving no basis to assess the parties' competing claims. The enforcement order was reversed and remanded for further proceedings.

For family law practitioners and parties in marital dissolution proceedings, this case underscores the critical need to create and preserve records of settlement conferences. Any party negotiating settlement terms should ensure formal documentation of agreed terms before finalizing agreements. The dissent noted that appeals should not serve as a do-over when a party fails to make a proper record below, suggesting litigants bear responsibility for establishing evidentiary records during trial court proceedings.

Source document (simplified)

Main Content

Case No. 24-1015

In re the marriage of Johnathon Sprague and Lanora Sprague

In this modification action, Lanora Sprague seeks further review of a court of appeals decision, which reversed the district court’s ruling to enforce a settlement agreement with Johnathon Sprague and remanded the case for an ancillary trial on the issue of whether the parties reached a settlement agreement.

County: Scott Trial Court Case No.: CDCD061019 Upon the Petition of Johnathon Sprague,
Resister

And Concerning Lanora Sprague,
Applicant

Attorney for Resister

Peter G. Gierut

Attorney for Applicant

Jennie L. Clausen

Brad Bonner

Supreme Court

Oral Argument Schedule

Non-Oral

Feb 18, 2026 1:30 PM

Briefs

Appellant Brief (219.54 KB)

Appellee Brief (250.53 KB)

Amicus Brief--Reforging Families (412.85 KB)

Supreme Court Opinion

Opinion Number:

24-1015

Date Published:

Apr 03, 2026

PDF of the Opinion (141.12 KB)

Court of Appeals

Court of Appeals Opinion

Opinion Number:

24-1015

Date Published:

Aug 06, 2025

Summary

Appeal from the Iowa District Court for Scott County, John Telleen, Judge. REVERSED AND REMANDED. Considered by Ahlers, P.J., and Badding and Buller, JJ. Telleen, S.J., takes no part. Opinion by Ahlers, P.J. Dissent by Buller, J. (13 pages)

Johnathon (John) Sprague appeals the district court’s order enforcing a settlement agreement drafted by his ex-wife, Lanora Sprague. John contends no binding settlement existed because the version enforced by the court omitted terms regarding the children’s transportation and extracurricular activities—terms he asserts were orally agreed to during an informal settlement conference. Lanora requests John to pay her appellate attorney fees. OPINION HOLDS: There is no record of the settlement conference, or the terms purportedly agreed to that day, nor is there a transcript or evidentiary record from the hearing on Lanora’s motion to enforce the settlement. As a result, we have no basis on which to assess the parties’ competing claims. Without an evidentiary record to support the district court’s decision, the order enforcing the settlement agreement is not supported by substantial evidence. Accordingly, we reverse the district court’s order granting Lanora’s motion to enforce settlement and remand for further proceedings. We deny Lanora’s request for appellate attorney fees. **** DISSENT ASSERTS: I dissent because appeals aren’t supposed to be do-overs after you fail to make a record below. In my view, the majority opinion decides this case backwards and reverses a district court ruling with inadequate record for us to conduct meaningful appellate review.

PDF of the Opinion (179.95 KB)