Robert M. Johnson, Trustee of the Robert M. Johnson Revocable Living Trust, and Kathryn M. Zimmer v. Des Moines Metropolitan Wastewater Reclamation Authority, Acting by and Through Its Operating Contractor, the City of Des Moines, 814 N.W.2d 240

Johnson Farms owns 65.93 acres of farmland bordering Ankeny Regional Airport.
PCAA condemned 4.17 acres in fee simple to extend Runway 22 and relocate Northeast 29th Street.
WRA condemned 0.92-acre permanent easement and 9.43-acre temporary construction easement adjacent to PCAA’s taking.
Condemnations were filed in 2010, four months apart, for two different projects from the same parent tract.
Johnson Farms moved under Iowa Rule of Civil Procedure 1.913 to consolidate the appeals for trial.
The district court consolidated the appeals, prompting this interlocutory appeal by PCAA and WRA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consolidation of the two condemnation appeals was an abuse of discretion.	Johnson Farms asserts common questions and judicial economy support consolidation.	PCAA and WRA contend there are no common questions and consolidation risks prejudice and confusion.	Yes, consolidation was an abuse of discretion; separate trials required.
Whether the two appeals present common questions of law or fact justifying consolidation.	Johnson Farms argues the same governing condemnation law applies and the land is the same parcel.	PCAA/WRA contend distinct takings and different valuations negate common questions.	Not sufficient; differing takings/yields and calculations undermine common questions.
Whether the benefits of consolidation outweigh the risks of prejudice and jury confusion.	Consolidation promotes economy and avoids inconsistent verdicts.	Consolidation risks inadmissible or confusing evidence and prejudice to the other party.	Prejudice and potential jury confusion outweigh benefits; consolidation abused.

Kent Feeds, Inc. v. Manthei, 646 N.W.2d 87 (Iowa 2002) (abuse of discretion standard; consolidation considerations)
Schupbach v. Schuknecht, 204 N.W.2d 918 (Iowa 1973) (discretion in consolidation rulings)
Everly v. Knoxville Cmty. Sch. Dist., 774 N.W.2d 488 (Iowa 2009) (abuse-of-discretion review and erroneous law treatment)
Williams, 201 N.W.2d 462 (Iowa 1972) (consolidation advantages and prejudice considerations)
Iowa Dev. Co. v. Iowa State Highway Comm’n, 252 Iowa 978 (Iowa 1961) (consolidation of condemnation appeals by multiple owners/tracts)
Van Horn v. Iowa Pub. Serv. Co., 182 N.W.2d 365 (Iowa 1970) (common questions of law or fact in consolidation)
Iowa Dev. Co. v. Iowa State Highway Comm’n, 252 Iowa 978 (Iowa 1961) (consolidation of condemnation appeals by multiple owners/tracts)
Heldenbrand v. Exec. Council, 218 N.W.2d 628 (Iowa 1974) (damages calculated as of appraisal date; before-after framework)
Jones v. Iowa State Highway Comm’n, 185 N.W.2d 746 (Iowa 1971) (before-and-after damages methodology)
Jones v. Iowa State Highway Comm’n, 259 Iowa 616, 144 N.W.2d 277 (Iowa 1966) (use of comparable sales and admissible evidence limits)
Graber v. City of Ankeny, 616 N.W.2d 633 (Iowa 2000) (abuse-of-discretion standard for consolidation)