Timothy L. Merriam, an Individual Justine Merriam, Both Individually and as Next Friend of Christopher Merriam, a Minor, Kayla Merriam, a Minor, and Collin Merriam, a Minor v. Farm Bureau Insurance, a Corporation and/or Farm Bureau Insurance Services, a Corporation and Steven C. Stonehocker, an Individual., 793 N.W.2d 520

Merriams sued insurance agent Steven Stonehocker and Farm Bureau insurers for negligence, alleging failure to advise on Timothy Merriam's need for self-employed workers’ compensation coverage.
Stonehocker, assigned to the Merriams in 2004, only serviced policies previously held with Farm Bureau and interacted with them in early 2005 regarding additional coverage.
In March 2005, Stonehocker met with the Merriams to discuss various coverages, and he obtained quotes for several items including a second residence, vehicles, and personal property; no workers’ compensation discussion occurred at that time.
Timothy Merriam, a self-employed over-the-road truck driver, was without workers’ compensation coverage through Landstar Ranger at the time of his March 29, 2005 injury.
The district court granted summary judgment finding no genuine issue that Stonehocker complied with a reasonable duty and that Farm Bureau was not vicariously liable.
On appeal, the Iowa Supreme Court affirmed, applying Langwith to determine whether an expanded agency agreement existed obligating Stonehocker to advise on workers’ compensation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Duty to advise on workers’ compensation	Merriam contends Stonehocker had an affirmative duty to inquire about workers’ comp given Timothy’s self-employment.	Stonehocker asserts no duty beyond procuring coverage; no expanded agency agreement shown.	No expanded duty; no duty to advise on self-employed workers’ compensation.
Existence of expanded agency agreement	Evidence of knowledge and unsolicited recommendations implies an expanded duty.	No long-term relationship or compensation beyond commission; no evidence of expanded services.	No genuine issue of material fact showing an expanded agreement.
Vicarious liability of Farm Bureau	Farm Bureau is liable for agent's negligent inaction as principal.	No duty breach by Stonehocker; no expanded agency; no respondeat liability absent duty.	No vicarious liability due to lack of expanded duty by agent.
Impact of prior cases on duty expansion	Langwith and related authorities support broader agent duties when client’s needs are apparent.	Langwith supports considering all circumstances but does not create automatic duty to assess all risks.	Agency duties require a qualifying agreement; none found here.
Fiduciary duty preserved for review	Merriams asserted fiduciary duty owed by defendants.	Fiduciary issue not preserved; if considered, no genuine issue of fiduciary duty.	Not preserved; even if considered, no genuine fiduciary duty.

Langwith v. Am. Nat’l Gen. Ins. Co., 793 N.W.2d 215 (Iowa 2010) (agency duty limited to coverage requested unless expanded by agreement)
Sandbulte v. Farm Bureau Mut. Ins. Co., 343 N.W.2d 457 (Iowa 1984) (circumstances under which expanded duties may arise)
Collegiate Mfg. Co. v. McDowell’s Agency, Inc., 200 N.W.2d 854 (Iowa 1972) (scope of agent's duties related to service agreements)