Mart v. Mart
Court of Appeals of Iowa
824 N.W.2d 535 (2012)
Mike Mart (defendant) leased a farm from his father under a 20-year lease. Some acreage was designated wetlands under the federal Swampbuster Act. After the father died and ownership passed to Mike and his siblings (plaintiffs), Mike planted corn on the protected wetlands, causing the federal government to deny the farm's owners $152,000 in benefits. The siblings appealed that penalty (unaware of Mike's violation) and got the benefits restored; the next year, Mike voluntarily restored the wetlands. The siblings then sought to cancel Mike's lease and filed for forcible entry and detainer. The trial court held Mike's Swampbuster violation did not constitute a breach of the farm lease, and the siblings appealed.
Whether a party's substantial compliance with the terms of a lease avoids a forfeiture, even if the party breaches the lease.