Dennis Langwith And Ben Langwith, Individuals v. American National General Insurance Company, A Corporation American National Property And Casualty Co., A Corporation And Janet Fitzgerald, Individually And D/b/a American National Janet Fitzgerald Insurance Services, 793 N.W.2d 215

Insurance agent Fitzgerald was a captive agent for American National; Langwiths relied on her for most insurance needs for a decade.
Ben Langwith’s driving led to an umbrella policy with Ben excluded after a driver exclusion was placed; Ben later reinstated, and Langwiths believed umbrella coverage remained.
Fitzgerald procured a high-risk automobile policy for Ben and did not disclose that the umbrella exclusion persisted; the Langwiths claimed they relied on her understanding of coverage.
Dennis and Ben were partially exposed in a personal injury suit stemming from Ben’s driving; American National defended under the automobile policy but denied umbrella coverage.
Plaintiffs alleged Fitzgerald breached duties of reasonable care by two acts: (a) failing to disclose the umbrella exclusion continued; (b) advising title transfer to Ben to avoid Dennis’s liability; the district court granted summary judgment to Fitzgerald and American National on these claims, which the court partially reversed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Fitzgerald owe an expanded duty to advise regarding umbrella coverage?	Langwiths alleged an expanded duty beyond mere procurement.	Fitzgerald’s duty was limited to procuring coverage unless an expanded agreement existed.	Genuine issue of material fact on expanded-duty claim; reversed in part.
Did Fitzgerald owe a duty to advise on risk-management or to suggest title transfer to avoid liability?	Langwiths argued Fitzgerald should have advised risk-avoidance measures.	No duty to advise on risk avoidance absent an expanded agreement.	No duty to advise on risk avoidance; claim affirmed for that aspect.
How should the agent’s duty be determined—by contract/undertaking or strict categorical rules?	Expanded duties could arise from long-standing relationship and reliance.	Duty confined to agreed services; no general expansion.	Adopt flexible, contract-based approach; overrule Sandbulte to the extent inconsistent.

Collegiate Mfg. Co. v. McDowell’s Agency, Inc., 200 N.W.2d 854 (Iowa 1972) (limited agent duties to procure requested coverage unless expanded by agreement)
Sandbulte v. Farm Bureau Mut. Ins. Co., 343 N.W.2d 457 (Iowa 1984) (expanded duties only with special relationship or explicit compensation for advice)
Humiston Grain Co. v. Rowley Interstate Transportation Co., 512 N.W.2d 573 (Iowa 1994) (professional-negligence standard; expert proof required for complex duties; distinguishes from simple procurement)
Smith v. State Farm Mut. Auto. Ins. Co., 248 N.W.2d 903 (Iowa 1976) (insurance agent must exercise reasonable skill and diligence; standard varies with context)