Seamans v. Kleiss

Court affirms easement ruling and damages award

The Iowa Court of Appeals’ June 2026 decision in Seamans v. Kleiss arose from a dispute over an easement agreement governing the purchase and land application of hog manure for agricultural use. A crop farmer had sold a small parcel of land for a hog facility and entered into a long-term easement agreement with the original operator, allowing the farmer to purchase and land apply the manure generated by the operation. 

A dispute arose after the hog facility changed ownership. The new owners did not honor the terms of the existing easement agreement, which led to conflicts over the crop farmer’s rights to access and remove manure. The crop farmer sued alleging breach of the easement agreement and tortious interference with contractual rights.

Following a bench trial, the district court ruled in favor of the crop farmer, granting specific performance of the easement, injunctive relief and awarding about $135,000 in damages, the cost of the replacement fertilizer. The district court found the defendants violated the easement agreement and interfered with the farmer’s contractual rights. On appeal, the hog barn owners challenged the district court’s interpretation of the easement, the finding of breach of the agreement, the damages award, and the conclusion that they tortiously interfered with the agreement.

The Iowa Court of Appeals rejected those arguments and affirmed the district court in full. The court found no error in the interpretation of the agreement, the factual findings, or the calculation of damages. As a result, the remedies awarded, including enforcement of the easement and monetary damages, remain in place.