In a case highlighting the critical importance of deadlines in indemnity claims, an Iowa farmer lost out on compensation after narrowly missing a statutory filing window.
On June 18, 2025, the Iowa Court of Appeals upheld a decision by the Iowa Grain Indemnity Fund Board denying a claim by soybean grower Scott Larson. Larson had sought indemnification for soybeans delivered to Global Processing Inc., a licensed grain dealer that filed for Chapter 11 bankruptcy. The court found that the title to the grain transferred more than six months before the bankruptcy filing date, making the claim ineligible under state law.
Between April 11 and 13, 2022, Larson delivered 5,648.71 bushels of soybeans to Global. On April 14, Global issued a settlement sheet showing no deductions for quality, moisture, or contamination. The sheet listed a net price of $87,525.89, after a $439.83 deduction for soybean checkoffs. A printed check was prepared for that amount and the sheet was stamped “PAID APR 14, 2022.” However, the check was never signed or sent.
When Global filed for bankruptcy on October 24, 2022, the Iowa Department of Agriculture identified it as the “incurrence date” for indemnity purposes. Under Iowa Code section 203D.6, a claim is eligible only if title to the grain transferred within six months of that date. The Board denied Larson’s claim on the basis that title had passed on April 14 - outside the allowed window.
Larson appealed, arguing that Global's right to review grain quality meant the transaction wasn’t finalized until May 14, 2022 - the date payment would have been due under their agreement. But the Board found that all indicators pointed to title transferring on April 14, citing the finalized pricing, lack of deductions, preparation of payment, and no return or rejection of grain.
The district court upheld that decision, and the Court of Appeals affirmed, concluding there was substantial evidence that title transferred on April 14. The court emphasized that under Iowa law, title can transfer even if payment isn’t made, and that Global’s failure to pay was more likely due to insolvency than any unresolved grain quality concerns.
Because Larson’s transaction occurred outside the six-month window, the Board’s denial stood. The case illustrates how critical transaction timing is in indemnity frameworks. Even with undisputed delivery and internal payment preparation, missing the eligibility window by a matter of days can cost claimants substantial reimbursement - up to 90% of the loss, capped at $300,000 under the fund’s rules.
For insurers and claims professionals involved in structured indemnity or insolvency-related coverage, the takeaway is clear: when timing determines coverage, every document matters, and every deadline counts.
