Christ Vision, Inc. v. City of Keokuk, 991 N.W.2d 543

Christ Vision owned a historic 1876 Unitarian church in Keokuk that fell into severe disrepair by the 2000s.
The city issued unsafe-to-occupy notices and, after a hearing, a December 2016 district-court order declared the building a nuisance and required Christ Vision to submit an abatement plan; if no plan was approved by March 2017, the city could abate or demolish.
Christ Vision did not submit an approved plan or seek an extension; the city notified the owner, contracted for demolition, removed asbestos, and began demolition in early 2018 (after a temporary injunction had been dissolved and before a subsequent hearing).
Christ Vision sued for inverse condemnation (taking), due process violations, trespass, and conversion of personal property; the district court granted summary judgment for the city on all claims after further briefing and discovery.
The owner admitted missing the abatement deadline and failed to present evidence that it sought access to remove personal property once demolition was imminent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Inverse condemnation / taking	Demolition of the building constituted a taking without just compensation.	Demolition was lawful exercise of police power to abate a nuisance; no compensable taking.	Affirmed: No taking—owner had no right to maintain a nuisance and city action fell within police powers.
Procedural due process	City destroyed property without required process (alleges chapter 657A procedures and claims injunction/effective stay).	Owner received notice and a full nuisance hearing; the December 2016 order authorized abatement; chapter 657A is not exclusive; no injunction was in effect.	Affirmed: No due-process violation.
Trespass	City wrongfully entered property to demolish and remove materials.	Entry was authorized by the unchallenged abatement order once owner missed deadline.	Affirmed: No trespass—city was justified by court order.
Conversion	City exercised wrongful dominion over personal property inside the church and denied access to remove it.	The abatement order authorized demolition (including fixtures); no evidence owner requested or was denied access; items taken earlier were treated as fixtures/real property.	Affirmed: No genuine issue of material fact; conversion claim fails.

Kingsway Cathedral v. Iowa Dep't of Transp., 711 N.W.2d 6 (Iowa 2006) (defines inverse-condemnation inquiry and protected property interests)
City of Eagle Grove v. Cahalan, 904 N.W.2d 552 (Iowa 2017) (police-power abatement of abandoned property not a compensable taking)
Lingle v. Chevron U.S.A., Inc., 544 U.S. 528 (2005) (distinguishes regulatory takings and excludes mere police-power regulation from takings analysis)
Lucas v. S.C. Coastal Council, 505 U.S. 1003 (1992) (per se regulatory takings rules)
Penn Cent. Transp. Co. v. New York City, 438 U.S. 104 (1978) (multi-factor balancing for regulatory takings)
Keystone Bituminous Coal Ass'n v. DeBenedictis, 480 U.S. 470 (1987) (government can assert police power to enjoin public harm without compensating owner)
Easter Lake Ests., Inc. v. Polk Cnty., 444 N.W.2d 72 (Iowa 1989) (no vested property right to maintain a nuisance)
Morrissey v. Brewer, 408 U.S. 471 (1972) (due-process notice and hearing principles)
Endress v. Iowa Dep't of Hum. Servs., 944 N.W.2d 71 (Iowa 2020) (procedural due process requires notice and opportunity to be heard)
State v. Van Rees, 246 N.W.2d 339 (Iowa 1976) (authority can justify entry that otherwise would be trespass)
Lewis v. Jaeger, 818 N.W.2d 165 (Iowa 2012) (conversion requires serious interference with possessory rights)