Residents of Royal View Manor by and Through Jeanette McDowell v. the Des Moines Municipal Housing Agency D/B/A Royal View Manor, 16-1230

Royal View Manor is a 200-unit, income-based apartment building owned/operated by the Des Moines Municipal Housing Agency (DMMHA).
Beginning in 2010 DMMHA engaged pest-control (Preferred Pest Control) and implemented quarterly inspections and treatments for an ongoing bed‑bug problem that affected many units intermittently over several years.
Plaintiffs (55 current/former residents) sued in October 2014 alleging breach of express, implied, and statutory warranties of habitability and sought class certification for tenants exposed to bed bugs from 2007 to present; the district court narrowed the class to tenants from January 1, 2010 to present.
The plaintiffs alleged a common course of conduct by DMMHA: renting units with knowledge of infestation, failing to disclose, and failing to reasonably remedy the infestation building‑wide.
The district court certified the class, finding numerosity, commonality/predominance, and that class treatment would be a fair and efficient adjudication; DMMHA appealed only the certification order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Numerosity — is joinder impracticable?	Class sizable (55 named; est. 300–600) and members low‑income/dispersed so joinder impractical	Sheer numbers not dispositive; argued joinder may be practical	Affirmed: 55 > threshold, court permissibly found impracticability considering numbers, resources, dispersion
Commonality / Predominance — do common questions predominate?	Liability turns on DMMHA’s common course of conduct re: building‑wide infestation and remediation efforts; one adjudication can resolve common issues	Individual proof required to show breach for each apartment; individualized issues predominate	Affirmed: common nucleus of operative fact (building‑wide infestation and DMMHA conduct) sufficiently predominates; damage variations do not defeat certification
Fair/efficient adjudication — will class procedure manage claims fairly?	Class avoids duplicative evidence, serves low‑income tenants with small individual recoveries, subclasses can manage variations	Individualized trials necessary for habitability determinations per unit	Affirmed: class treatment promotes judicial economy and fairness; district court can create subclasses if needed
Adequacy of representatives — will named plaintiffs protect class interests?	55 named plaintiffs demonstrate representation and resources to litigate	(DMMHA did not persuasively contest adequacy)	Affirmed: no reason to believe representatives are inadequate

Freeman v. Grain Processing Corp., 895 N.W.2d 105 (Iowa 2017) (standard of review and discretionary class‑certification factors)
Legg v. West Bank, 873 N.W.2d 756 (Iowa 2016) (presumption of impracticability when class has forty or more members)
City of Dubuque v. Iowa Trust, 519 N.W.2d 786 (Iowa 1994) (resolve doubts about joinder impracticability in favor of certification)
Comes v. Microsoft Corp., 696 N.W.2d 318 (Iowa 2005) (objectives of class actions and Rule prerequisites)
Amchem Prods., Inc. v. Windsor, 521 U.S. 591 (1997) (policy underpinning class action to aggregate small claims for effective litigation)
Luttenegger v. Conseco Fin. Servicing Corp., 671 N.W.2d 425 (Iowa 2003) (pragmatic predominance test; common questions need not be identical)
Pa. Emps.’ Ret. Sys. v. Morgan Stanley & Co., 772 F.3d 111 (2d Cir. 2014) (factors for impracticability: financial resources and geographic dispersion)