Central Iowa Investors, L.C. v. Brookstone Specialty Services, Inc.
24-1185
| Iowa Ct. App. | Aug 6, 2025Background
- Central Iowa Investors, L.C. (CII) owned a commercial building in Ames, Iowa, leased from 2013 to 2022 by Brookstone Specialty Services, Inc. (Brookstone) for use as a truck and trailer wash and installation shop.
- The lease assigned responsibility for structural repairs to CII and all other repairs and maintenance to Brookstone, requiring the premises be returned in good, clean condition except for ordinary wear and tear.
- After the lease ended in May 2022, Brookstone vacated the premises, but CII alleged the building was left damaged and not in the required condition; attempts to renew or settle were unsuccessful.
- CII sued Brookstone for breach of contract seeking over $400,000 in repair costs, lost rent, and attorney fees and costs; the district court awarded much less ($1050 initially, then $20,000 after reconsideration), denying attorney fees due to minimal recovery.
- On appeal, the Iowa Court of Appeals reviewed whether damages were properly limited, if lost rent was correctly denied, and whether attorney fees should have been awarded under the lease.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Damages for Building Repairs | Brookstone caused damage; CII entitled to large repair cost reflecting return to prior condition | Building was structurally sound; repair value unsupported and speculative | Court affirmed limited damages; large claim lacked adequate evidence |
| Lost Rental Income | CII could not re-rent due to building’s condition; seeks 18 months' lost rent | Building was usable; CII’s family used it for storage post-tenancy | No additional lost rent awarded; evidence did not support claim |
| Attorney Fees and Court Costs | Lease allows recovery if Brookstone defaulted and CII prevailed | Minimal success does not entitle fees; disputed scope of fee provision | Reversed; attorney fees allowed for rent recovery and possession efforts |
| Measure and Proof of Damages | Cost to repair is proper measure for restoration | Value and condition at start/end not shown; speculative calculation | Cost of repair cannot exceed value; required proof of condition/value |
Key Cases Cited
- St. Malachy Roman Cath. Congregation v. Ingram, 841 N.W.2d 338 (Iowa 2013) (Party seeking damages bears burden of proof; speculative damages not recoverable)
- Hendricks v. Great Plains Supply Co., 609 N.W.2d 486 (Iowa 2000) (Measure of damages for property harm is cost of restoration, not exceeding pre-damage value)
- D.R. Mobile Home Rentals v. Frost, 545 N.W.2d 302 (Iowa 1996) (Error to award damages without evidence damages were sustained)