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Frontier Leasing Corporation, Assignee From C & J Vantage Leasing, Assignor Vs. Treynor Recreation Area

Citation: Not availableDocket: 09–0123

Court: Supreme Court of Iowa; March 19, 2010; Iowa; State Supreme Court

Original Court Document: View Document

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Frontier Leasing Corporation appealed a decision from the Iowa Court of Appeals, which upheld a district court ruling that deemed Frontier's assignments of a lease with Treynor Recreation Area invalid. The underlying issue involved whether Frontier, as an assignee, had the right to recover damages from Treynor for defaulting on an equipment lease originally between Treynor and C and J Leasing Corporation. The district court concluded that errors in the assignment chain meant Frontier was not the real party in interest and dismissed the petition.

The Court of Appeals affirmed this dismissal, stating that Frontier lacked an enforceable interest in the lease. Upon review, the Supreme Court of Iowa vacated part of the Court of Appeals' decision, specifically the instruction for a reasonable period for substitution of the real party in interest. The Supreme Court held that Treynor should have the opportunity to demonstrate any potential prejudice resulting from a substitution under Iowa Rule of Civil Procedure 1.201. 

The Supreme Court remanded the case to the district court, which must evaluate whether substitution is appropriate and determine the timing for such action. If substitution is granted, the case will proceed to merits consideration; if not, the district court's judgment will remain in effect. The opinion is not to be published.