STATE COURT COMPLAINT – BREACH OF CONTRACT
(Iowa District Court)

[// GUIDANCE: This template is drafted to comply with the Iowa Rules of Civil Procedure (Iowa R. Civ. P. 1.301-1.453) and incorporates Iowa-specific pleading, service, and discovery considerations. Citations provided are to well-established, non-controversial rules only. Customize all bracketed text, exhibits, and optional sections before filing.]

TABLE OF CONTENTS

1. Caption
2. Petition at Law and Equity
   2.1 Introduction
   2.2 Parties
   2.3 Jurisdiction & Venue
   2.4 Factual Allegations
   2.5 Count I – Breach of Contract
   2.6 [Count II – Unjust Enrichment (Optional)]
   2.7 Damages
   2.8 Conditions Precedent / Excuse of Performance
   2.9 Demand for Jury Trial (Optional)
   2.10 Prayer for Relief
   2.11 Designation of Service Address
3. Signature Block (Rule 1.413(1)–(2))
4. Verification (Optional)
5. Certificate of Service (Post-filing Documents)
6. Exhibit Index
7. Original Notice (for Service pursuant to Rule 1.302)

1. CAPTION

IN THE IOWA DISTRICT COURT FOR [__] COUNTY

[PLAINTIFF LEGAL NAME],
Plaintiff,

v. No. __

[DEFENDANT LEGAL NAME],
Defendant.
PETITION AT LAW AND EQUITY
(BREACH OF CONTRACT)

2. PETITION AT LAW AND EQUITY

2.1 Introduction

1. Plaintiff brings this civil action for breach of contract and related relief arising from Defendant’s failure to perform under the parties’ written agreement dated [DATE] (the “Contract”).

2.2 Parties

2. Plaintiff – [full legal name, entity type, state of organization/residence, principal place of business].
3. Defendant – [full legal name, entity type, state of organization/residence, principal place of business].

2.3 Jurisdiction & Venue

4. This Court has subject-matter jurisdiction under Iowa Code § 602.6101 and Iowa R. Civ. P. 1.601 because the amount in controversy exceeds $300 and the claims arise under Iowa contract law.
5. Venue is proper in [__] County under Iowa R. Civ. P. 1.801(2) because (a) the Contract was to be performed in this county, and/or (b) Defendant resides/does business here.

2.4 Factual Allegations

6. On [DATE], Plaintiff and Defendant executed the Contract, attached hereto as Exhibit A.
7. Under the Contract, Defendant agreed to:
   a. [Describe primary obligations];
   b. [Describe secondary obligations].
8. Plaintiff fully performed, or was ready, willing, and able to perform, all material obligations under the Contract.
9. Beginning on or about [DATE], Defendant materially breached the Contract by:
   a. [Failure to pay $_____ by due date];
   b. [Failure to deliver goods/services meeting specifications]; and
   c. [Any other breaches].
10. Plaintiff provided written notice of breach on [DATE] and afforded Defendant a [__-day] contractual cure period, which expired without cure. See Exhibit B.
11. As a direct and proximate result of Defendant’s breaches, Plaintiff has suffered damages in excess of $[AMOUNT], exclusive of interest, costs, and attorney fees.

2.5 Count I – Breach of Contract

12. Plaintiff incorporates ¶¶1-11 as if fully set forth herein.
13. A valid, enforceable Contract exists between the parties.
14. Plaintiff performed all conditions precedent or such conditions have been waived or excused.
15. Defendant’s acts and omissions constitute material breaches of the Contract.
16. Plaintiff is entitled to recover all actual, consequential, and incidental damages, pre- and post-judgment interest, costs, and contractually-authorized attorney fees.
17. In the alternative, specific performance and/or injunctive relief is warranted because monetary damages are inadequate to make Plaintiff whole with respect to [describe unique goods/irreparable harm].

2.6 [Count II – Unjust Enrichment (Optional)]

18. Plaintiff realleges ¶¶1-11.
19. Defendant received and retained benefits conferred by Plaintiff under circumstances rendering it unjust to permit Defendant to retain those benefits without payment.
20. Plaintiff seeks restitution in an amount to be proven at trial.

2.7 Damages

21. Plaintiff seeks:
    a. Direct damages of $[__];
    b. Consequential damages, including lost profits of $[_];
    c. Pre-judgment interest at the contract rate of % (or statutory rate, Iowa Code § 535.3);
    d. Post-judgment interest;
    e. Reasonable attorney fees and costs as provided in ¶[__] of the Contract; and
    f. Equitable relief as the Court deems just.

2.8 Conditions Precedent / Excuse of Performance

22. All conditions precedent to Defendant’s duties have occurred, been performed, or been waived. Alternatively, Defendant’s prior material breach excuses any further performance by Plaintiff.

2.9 Demand for Jury Trial (Optional)

23. Pursuant to Iowa R. Civ. P. 1.904(2), Plaintiff hereby demands trial by jury on all issues so triable.

2.10 Prayer for Relief

WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in its favor and against Defendant as follows:
A. Awarding damages as set forth in ¶21;
B. Ordering specific performance and/or temporary, preliminary, and permanent injunctive relief as necessary to prevent further harm;
C. Awarding contractual attorney fees, court costs, and disbursements;
D. Taxing interest as allowed by law; and
E. Granting such other and further relief the Court deems just and proper.

2.11 Designation of Service Address

All papers required to be served on Plaintiff shall be sent to:
[LAW FIRM NAME]
Attn: [Attorney Name], AT000[_ ]
[Street Address] | [City], IA [ZIP]
Phone: () - | Email: [_]

3. SIGNATURE BLOCK (Iowa R. Civ. P. 1.413(1)–(2))

Respectfully submitted,

[LAW FIRM NAME]

By: ______
[ATTORNEY NAME], AT000[ ]
Attorneys for Plaintiff
[Street Address]
[City], IA [ZIP]
Telephone: () -_
Facsimile: () -_
Email: [_____]

4. VERIFICATION (Optional – use if contract or statute requires)

STATE OF IOWA )
) SS:
[COUNTY] )

I, [PLAINTIFF REPRESENTATIVE], being first duly sworn upon oath, depose and state that I am the [title/position] of Plaintiff; I have read the foregoing Petition and know the contents thereof; and the statements therein are true and correct to the best of my knowledge, information, and belief.

[Name], [Title]
Subscribed and sworn before me on this ___ day of _, 20.

Notary Public in and for the State of Iowa
[// GUIDANCE: Verification is generally not required under Iowa R. Civ. P. unless a statute or special rule so mandates. Delete if unnecessary.]

5. CERTIFICATE OF SERVICE

[// GUIDANCE: Original petitions are served with an Original Notice (similar to a summons) under Rule 1.302; no certificate of service is required until after a defendant appears. Retain this template for future filings.]

The undersigned certifies that on _, 20, the foregoing document was filed via EDMS and served upon all parties of record electronically.

[Attorney Name]

6. EXHIBIT INDEX

Exhibit A – Executed Contract
Exhibit B – Notice of Default/Cure Letter
Exhibit C – Damage Summary [if available]

[// GUIDANCE: Attach each exhibit as a separate, clearly-labeled PDF when filing via Iowa EDMS.]

7. ORIGINAL NOTICE

[// GUIDANCE: This must accompany the Petition when served. Tailor to the clerk-approved language in Iowa R. Civ. P. 1.302(1).]

IN THE IOWA DISTRICT COURT FOR [__] COUNTY

[PLAINTIFF], )
Plaintiff, )
) No. __
v. )
) ORIGINAL NOTICE
[DEFENDANT], )
Defendant. )

TO THE ABOVE-NAMED DEFENDANT:

You are notified that a petition has been filed in the office of the clerk of this court naming you as the defendant in this action, which petition prays for judgment against you in the amount of $[_____] plus interest, costs, and other relief. A copy of the petition (and any documents filed with it) is attached to this notice.

You must serve a motion or answer within 20 days after service of this Original Notice upon you. If you fail to respond, judgment by default may be rendered against you for the relief demanded in the petition.

[Insert EDMS Registration Notice per Rule 16.302(1)(e) if serving a registered user.]

Clerk of Court
[Clerk’s Address]
[County], Iowa

ADDITIONAL PRACTICE NOTES

[// GUIDANCE:
1. Pleading Requirements – Iowa follows notice pleading. Include only ultimate facts; detailed evidence is unnecessary (Rule 1.402).
2. Service – Original Notice must be served within 90 days after filing (Rule 1.302(5)). Track service deadline.
3. Discovery Limits – Iowa generally mirrors the federal rules but imposes presumptive limits (e.g., 30 interrogatories, Rule 1.509(2)). Consider agreeing to modified limits in the discovery plan (Rule 1.507).
4. Jury Deposit – If demanding a jury, the $100 jury fee must be paid at filing (Iowa Code § 625.16).
5. Electronic Filing – All pleadings must be filed through EDMS; preserve confidentiality designations for exhibits containing sensitive data.]

END OF TEMPLATE