In re Chapman

Judith Chapman (plaintiff) purchased and moved into a mobile home. Chapman later transferred title to the mobile home to her son, John Wilkinson (defendant), telling him that the home was to be his inheritance when she died. Judith simultaneously transferred a duplex to her two daughters, essentially depleting her net worth. Several years later, one of Chapman’s daughters moved into the mobile home with her. Unhappy, Wilkinson asked Chapman to pay him $35,000 to transfer title back to her. Chapman refused, saying that the mobile home was to be Wilkinson’s inheritance and he could sell it when she died. Wilkinson began posting eviction notices on the mobile home’s door, demanding that Chapman and her daughter vacate the property. Wilkinson eventually involved the police. Two deputies visited the home but informed Wilkinson that the dispute was a civil matter, not a criminal one. Upset by Wilkinson’s actions, Chapman sued him for elder abuse, seeking an elder-abuse protective order. Chapman complained that at 69, she was too old to deal with the stress Wilkinson was causing. The district court held in Chapman’s favor, holding that Wilkinson had financially exploited Chapman by failing to recognize her life estate, meaning her right to live in the property for life. Wilkinson appealed, arguing that the elder-abuse statute did not apply because (1) Chapman, who had no physical or mental issues, was not a vulnerable elder and (2) Wilkinson was not Chapman’s caretaker. The state appeals court affirmed, finding that Chapman’s age alone rendered her a vulnerable elder and that a person could violate the statute even if not the elder’s caretaker. Wilkinson appealed to the Iowa Supreme Court.