Estate of Dorothy Harris v. Randall Everett Harris, His Unknown Spouses, Heirs, Devisees, Grantees, Assignees, Successors in Interest and Their Unknown Spouses and the Parties in Possession and Unknown of the Following Described Real Estate Situated in Floyd County, Iowa, 16-0408

In March 2011 Dorothy Harris executed and recorded a quitclaim deed conveying her 13-acre home to her son Randall for $1; she died in August 2012.
Medical records and testimony from 2008–2011 showed progressive dementia/Alzheimer’s, poor hygiene, inability to care for a leg wound, and placement in rehabilitation/nursing care shortly before the deed.
Attorney Schwickerath prepared the deed after a short meeting (15–20 minutes alone with Dorothy); he was unaware of her dementia diagnosis or her will.
Family members and medical providers testified Dorothy had significant cognitive decline; Randall and his witnesses disputed the extent but admitted short-term memory issues.
The Estate sued to quiet title, alleging Dorothy lacked capacity; the district court set aside the deed as void, finding the Estate proved lack of capacity by clear, convincing, and satisfactory evidence.
On appeal the Iowa Court of Appeals reviewed de novo, gave weight to trial credibility findings, and affirmed the district court; appellate attorney fees were denied to both parties for lack of supporting authority.

Issue	Estate's Argument	Randall's Argument	Held
Whether Dorothy had mental capacity to execute the quitclaim deed	Dorothy lacked sufficient mental capacity in March 2011 to understand/handle her financial affairs; medical testimony and contemporaneous observations show dementia and incapacity	Dorothy (via Randall) was of sound mind for the transaction; short-term memory lapses did not preclude understanding; attorney found her able to comprehend	Court affirmed: Estate proved lack of capacity by clear, convincing, and satisfactory evidence; deed set aside as void
Whether appellate attorney fees should be awarded	Estate requested fees ($2000)	Randall requested fees ($4000)	Denied to both: neither cited legal authority supporting fee award

Daughton v. Parson, 423 N.W.2d 894 (Iowa Ct. App. 1988) (party alleging lack of capacity must prove it by clear, convincing, satisfactory evidence)
Costello v. Costello, 186 N.W.2d 651 (Iowa 1971) (definition of mental capacity to understand import of acts)
In re Estate of Baessler, 561 N.W.2d 88 (Iowa Ct. App. 1997) (capacity principles applied in estate/deed challenges)
Brewster v. Brewster, 188 N.W. 672 (Iowa 1922) (factors relevant to capacity: physical condition, consideration, improvidence, trust relationship, prior/subsequent acts)
In re Estate of Herm, 284 N.W.2d 191 (Iowa 1979) (lack of independent advice is relevant to capacity)
Jackson v. Schrader, 676 N.W.2d 599 (Iowa 2003) (noting limits/abrogation of prior authority on related issues)