Klinge v. Bentien

John Klinge (plaintiff) and Kevin Bentien (defendant) were Iowa farmers who entered into an oral agreement with each other. Bentien purchased feeder pigs to be cared for on Klinge’s farm until the pigs reached market weight. At some point, Klinge’s conduct resulted in the death of 100 pigs. Klinge sued Bentien in small-claims court to recover $3,000 under their agreement. Bentien countersued for $5,000 based on Klinge’s alleged negligence. The parties were not represented by counsel, and neither one requested mediation of their dispute with the farm mediation service pursuant to an applicable section of the Iowa Code. The small-claims court entered judgment as requested, awarding $3,000 for Klinge and $5,000 for Bentien. Klinge appealed the judgment against him, while Bentien did not. The appellate court found that neither judgment was supported by sufficient evidence and reversed the judgment against Klinge but took no action as to the judgment against Bentien, who had not appealed. Soon thereafter, Bentien consulted an attorney for the first time. Bentien’s attorney alerted the appellate court that both parties had failed to request mediation of the dispute. The appellate court declined to take further action. Bentien requested discretionary review, and the Iowa Supreme Court granted the request. Bentien argued that both parties’ claims should be dismissed because the lower courts lacked subject-matter jurisdiction to hear the cases.