In the Matter of the Estate of Carroll Irving Sampson, Cheryl Ann Murken and Mary Ann Smith, Coexecutors of the Christine Rosilia Sampson Estate, 838 N.W.2d 663

In 1993 Carroll Sampson died; his will left the farmland to Christine as survivor, with siblings and their descendants potentially entitled under article four.
Carroll’s estate was probated, Christine was appointed executor, and final report/listing showed Christine as sole beneficiary; estate closed in 1994.
Relatives who were not notified of the 1993 probate learned of the will after Christine’s 2011 death and sought to reopen Carroll’s estate.
Relatives argued for reopening under Iowa Code § 633.489, claiming a different residuary interest entitled them to property; Christine’s executors argued § 633.488 applied and barred claims.
District court denied summary judgment for the relatives, concluding § 633.489 governed; court of appeals agreed; Supreme Court grants review.
The Court ultimately holds § 633.488 applies to a petition to reopen settlement (redistribution of property), not § 633.489, which governs administration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Which statute governs reopening here	Sampson relatives argue § 633.489 applies.	Coexecutors contend § 633.488 governs reopening settlement.	§ 633.488 governs; not time-barred under five years.
Does lack of notice affect applicability	Relatives were deprived of notice, enabling reopening.	Notice issues do not alter § 633.489 framework.	Notice does not alter § 633.489’s applicability; irrelevant to statutory boundary.
Scope of 'other proper cause' in § 633.489	Broadly read to allow redistribution when heirs were previously deprived.	Limited to administration acts or discovery; cannot redistribute absent unperformed acts.	Interpret 'other proper cause' narrowly; does not authorize redistribution of property.
Relation to prior precedents on reopening	Roethler and Warrington support reopening for missed opportunities.	Those decisions do not permit redistributive relief under § 633.489.	Precedents support administration/undiscovered-property focus; not settlement redistribution.

Ritz v. Selma United Methodist Church, 467 N.W.2d 266 (Iowa 1991) (distinguishes 633.488 (settlement) from 633.489 (administration))
In re Estate of Lynch, 491 N.W.2d 157 (Iowa 1992) (mistake in fees may warrant reopening; administration context)
In re Estate of Warrington, 686 N.W.2d 198 (Iowa 2004) (invasion of life estate; administration context after closing)
In re Estate of Roethler, 801 N.W.2d 833 (Iowa 2011) (reopening for option not previously noticed; administration scope)
In re Estate of Witzke, 359 N.W.2d 183 (Iowa 1984) (administration discretion; proper-cause standard)