U.S. Bank, National Association v. Jeffrey S. Bittner, Individually and as Trustee of the Joan Y. Bittner Marital Trust and Midwestone Bank, as Conservator of the Joan Y. Bittner Marital Trust, 986 N.W.2d 840

R. Richard Bittner (decedent) died in 2019 leaving an IRA (≈$3M), a 2010 will, a 2010 typed IRA beneficiary addendum, and a 2014 will that revoked the 2010 will.
The 2010 IRA addendum listed Joan Y. Bittner (wife) as "Primary Beneficiary — 100%" but also referenced the "Joan Y. Bittner Marital Trust," marital-deduction funding language, and listed the four children as contingent beneficiaries.
The 2014 will modified estate directions and referred to distributions being governed by the beneficiary designation on file with U.S. Bank; the 2010 will was revoked.
After Richard’s death U.S. Bank (IRA trustee) filed for declaratory judgment seeking to transfer the IRA to Joan; three children agreed, but Jeffrey (one child) objected, claiming the marital/family trust should receive the IRA and asserting conflict issues.
The district court ruled the IRA designation was unambiguous and awarded the IRA to Joan; the court of appeals affirmed. The Iowa Supreme Court granted further review, held the trial court should consider extrinsic evidence but—after examining Jeffrey’s offer of proof—concluded the addendum unambiguously conveyed the IRA to Joan and affirmed.

Issue	Plaintiff's Argument (Jeffrey)	Defendant's Argument (U.S. Bank / Joan / Conservator)	Held
Proper beneficiary of the IRA (interpretation of the 2010 addendum)	The addendum must be read with the 2010 will and extrinsic evidence to show Richard intended the Marital/Family Trust to be the primary beneficiary	The typed addendum names Joan individually as 100% primary beneficiary; the IRA agreement controls and is unambiguous	Court: Trial court should consider extrinsic evidence, but after review the addendum unambiguously names Joan as primary beneficiary; award to Joan affirmed
Whether U.S. Bank improperly filed declaratory judgment or had disqualifying conflict (vs. interpleader)	U.S. Bank had a conflict as co‑executor and IRA trustee and should not have prosecuted declaratory action; interpleader required	Declaratory judgment was permissible; interpleader is discretionary, conservator participated, and any conflict did not mandate a retrial	Court: No reversible error; declaratory action acceptable and any conflict did not require a do‑over

Pillsbury Co. v. Wells Dairy, Inc., 752 N.W.2d 430 (Iowa 2008) (adopts Restatement approach to parol evidence and when extrinsic evidence may inform contract meaning)
Soults Farms, Inc. v. Schafer, 797 N.W.2d 92 (Iowa 2011) (contract meaning requires context; extrinsic evidence may be considered)
Alta Vista Props., LLC v. Mauer Vision Ctr., PC, 855 N.W.2d 722 (Iowa 2014) (apply ordinary contract principles and consider agreement as whole plus relevant extrinsic evidence)
Colwell v. MCNA Ins., 960 N.W.2d 675 (Iowa 2021) (standard of review and when interpretation raises factual issues requiring a factfinder)
In re Estate of Gantner, 893 N.W.2d 896 (Iowa 2017) (IRA is a non‑probate asset; beneficiary designation controls over will for IRA disposition)
Taylor Enter., Inc. v. Clarinda Prod. Credit Ass’n, 447 N.W.2d 113 (Iowa 1989) (writings executed as part of same transaction should be construed together)