Serena Konrardy and Carrie Rigdon, n/k/a Carrie Burmeister v. Vincent Angerer Trust and Dewitt Bank and Trust Company, as Trustee of the Vincent Angerer Trust, 925 N.W.2d 620

Vincent Angerer created a trust in 1998 dividing equal shares among five siblings; when a sibling and spouse predeceased him, that share was payable to the sibling's descendants.
Angerer died May 30, 2010; two plaintiffs (grandchildren of predeceased sibling Cecelia Howard) received immediate distributions in October 2011 based on estate value as of date of death and signed waivers/releases at distribution.
Plaintiffs later alleged they were treated differently and underpaid because farmland appreciated after death; their attorney sent a demand letter Aug 11, 2015; trustee replied Aug 19, 2015 with a letter and enclosures showing valuation as of date of death and accountings.
Plaintiffs filed suit Mar 15, 2017 seeking revaluation as of distribution date; defendants moved for summary judgment arguing (1) statute of limitations under Iowa Code §633A.4504 bars the claim and (2) trust language requires valuation at date of death.
District court denied summary judgment, finding factual disputes about whether plaintiffs received an accounting that adequately disclosed the claim and whether the release waived claims; court of appeals affirmed on interlocutory appeal.
Iowa Supreme Court granted further review and reversed: it held the Aug 19, 2015 letter constituted a report/accounting that adequately disclosed the claim and triggered the one-year limitations period, so plaintiffs’ suit (filed in March 2017) was untimely.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiffs’ suit is barred by the one-year limitations period in Iowa Code §633A.4504	Plaintiffs sought trust construction, not a breach-of-trust claim, so statute inapplicable; also argued the trustee’s postdistribution correspondence was not an "accounting" triggering the limitation	§633A.4504 applies to breach-of-trust claims; the trustee’s Aug 19, 2015 letter and enclosures were a "report" that adequately disclosed the claim and started the one-year clock	Held: Statute applies; Aug 19, 2015 letter was a report that adequately disclosed the claim; suit filed more than one year later is barred
Whether trust language clearly requires valuation as of date of death (merits)	Plaintiffs argued distributions should have been valued at date of distribution (Oct 2011)	Defendants argued trust unambiguously required valuation at decedent’s date of death (May 2010)	Court did not reach merits because claim barred by limitation; merits not decided

Jahnke v. Deere & Co., 912 N.W.2d 136 (Iowa 2018) (standard for summary judgment)
Homan v. Branstad, 887 N.W.2d 153 (Iowa 2016) (summary judgment standard and material fact analysis)
Turner v. Iowa State Bank & Tr. Co., 743 N.W.2d 1 (Iowa 2007) (trustee’s duty to administer per terms of trust)
Zimmer v. Vander Waal, 780 N.W.2d 730 (Iowa 2010) (substance over label in characterizing claims)