In re Marriage of Kraus, 19 N.W.3d 712

Matthew and Molly Kraus divorced in November 2022, with Molly receiving physical custody and Matthew visitation and support rights via a stipulated decree.
Fifty-one days post-divorce, Matthew filed a petition to modify the custody and support terms, claiming a material and substantial change in circumstances.
During discovery, Matthew admitted he sought modification solely because he regretted the original agreement, not due to any changed circumstances.
Molly moved for sanctions under Iowa Rule of Civil Procedure 1.413, arguing Matthew’s petition was frivolous and not filed in good faith.
The district court found Matthew’s petition violated Rule 1.413, dismissed the modification petition as a sanction, and ordered Matthew to pay $7,226.65 in attorney fees.
Matthew appealed, challenging the applicability and amount of sanctions and the authority of the court to dismiss his petition under Rule 1.413.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of Rule 1.413 to family law cases	Rule shouldn’t apply to family law	Rule 1.413 applies to all civil cases	Rule 1.413 applies to family law cases
Timeliness of sanctions motion	Motion was untimely	Timely; sought after discovery	No error; motion was timely
Appropriateness and amount of attorney fee sanction	Fees too high; no income disparity	Fees based on uncontested affidavit	Sanction amount/approach affirmed
Dismissal as a sanction under Rule 1.413	Dismissal was not permitted	Rule allows for any appropriate sanction	Dismissal not permitted under Rule 1.413; reversed

Mathias v. Glandon, 448 N.W.2d 443 (Iowa 1989) (sets sanction standard under Iowa Rule 1.413)
K. Carr v. Hovick, 451 N.W.2d 815 (Iowa 1990) (Rule 1.413 does not authorize dismissal as a sanction)
Rowedder v. Anderson, 814 N.W.2d 585 (Iowa 2012) (secondary purpose of Rule 1.413 includes compensating parties victimized by misconduct)
Barnhill v. Iowa Dist. Ct., 765 N.W.2d 267 (Iowa 2009) (outlines duties required under Rule 1.413)