The Estate of Susan Farrell, by its Administrator, Jesse Farrell, and as Representative for the Claims of Jesse Farrell, Individually, Jesse Farrell, as Next Friend of R.F., a Minor, Margaret Renee Maschske, Individually, & Stephen Michalski, Individually v. State of Iowa, City of Waukee, Iowa, and City of West Des Moines, Iowa, 974 N.W.2d 132

Iowa, Waukee, and West Des Moines designed and built Iowa’s first diverging diamond interchange (DDI) at I-80/Alice’s Road and opened it Dec. 1, 2015 while lighting, signage, and markings remained incomplete.
Plaintiffs allege the DDI’s confusing design and the premature opening created a dangerous condition that induced Benjamin Beary to drive the wrong way on I-80 in March 2016, causing a fatal head-on collision that killed Officer Susan Farrell and others.
Plaintiffs sued the Cities and State for negligence, nuisance, and premises liability based on design, construction, operation, and failure to close the interchange; government defendants asserted the public-duty doctrine and moved for judgment on the pleadings.
The district court denied judgment on the pleadings, concluding allegations of governmental misfeasance creating a dangerous condition avoided the public-duty doctrine; the court did not resolve special-relationship or egregious-conduct arguments.
The court of appeals reversed, applying the public-duty doctrine; the Iowa Supreme Court granted further review, accepted pleaded facts as true, vacated the court of appeals, and affirmed the district court’s denial of judgment on the pleadings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Iowa should abolish the public-duty doctrine	Abolish doctrine as inconsistent with Tort Claims Acts	Preserve doctrine; long-standing precedent	Court declines to abolish; doctrine remains
Whether public-duty doctrine bars tort claims here	Farrell: defendants’ affirmative negligence (misfeasance) created dangerous condition on gov’t property, so doctrine inapplicable	Gov’t: duty was to the public at large; harm caused by a third party so doctrine bars claims	Misfeasance exception applies; doctrine does not bar these pleaded claims
Whether third-party wrongdoer (Beary) is an intervening/superseding cause	Plaintiffs: Beary’s conduct was intertwined with interchange’s dangerous design; both are instrumentalities of harm	Defendants: focus on Beary as sole instrumentality; public-duty should shield them	Beary’s conduct does not absolve gov’t; both interchange and vehicle are instrumentalities of harm
Whether special-relationship or egregious-conduct exceptions are required to avoid doctrine	Plaintiffs: special-relationship and egregious-conduct exceptions apply	Defendants: no special relationship; exceptions inapplicable	Court did not decide; unnecessary because misfeasance ruling resolves JOP motion

Fulps v. City of Urbandale, 956 N.W.2d 469 (Iowa 2021) (misfeasance/dangerous-condition on city property avoids public-duty defense)
Breese v. City of Burlington, 945 N.W.2d 12 (Iowa 2020) (city liable for hazardous bike-path condition despite public-duty doctrine)
Raas v. State, 729 N.W.2d 444 (Iowa 2007) (public-duty doctrine distinct from statutory immunity; doctrine survives Tort Claims Acts)
Est. of McFarlin v. State, 881 N.W.2d 51 (Iowa 2016) (reiterating public-duty doctrine remains despite tort-claims statutes)
Johnson v. Humboldt County, 913 N.W.2d 256 (Iowa 2018) (distinguishing failures to act from affirmative negligent acts creating dangers)
Griffioen v. Cedar Rapids & Iowa City Ry., 914 N.W.2d 273 (Iowa 2018) (standard for reviewing judgment-on-the-pleadings)
State v. Shears, 920 N.W.2d 527 (Iowa 2018) (intentional third-party act not necessarily an intervening, superseding cause)