{
  "type": "practice-guide",
  "canonical": "https://openagreements.org/practice-guides/invention-assignment/us/iowa",
  "links": [
    {
      "rel": "self",
      "href": "https://openagreements.org/practice-guides/invention-assignment/us/iowa.json",
      "type": "application/json"
    },
    {
      "rel": "alternate",
      "href": "https://openagreements.org/practice-guides/invention-assignment/us/iowa",
      "type": "text/html"
    },
    {
      "rel": "alternate",
      "href": "https://openagreements.org/practice-guides/invention-assignment/us/iowa/markdown",
      "type": "text/markdown"
    },
    {
      "rel": "alternate",
      "href": "https://openagreements.org/practice-guides/invention-assignment/us/iowa/json",
      "type": "application/json"
    }
  ],
  "data": {
    "topic": "invention-assignment",
    "state": "iowa",
    "frontmatter": {
      "title": "Employee Invention Assignment in Iowa",
      "description": "Iowa has no employee-invention-assignment statute, so an assignment clause is bounded only by ordinary contract law, the common-law default rules, and the reasonableness limits Iowa applies to restraints arising from employment — not a California-style own-time carve-out or notice requirement. Absent a written assignment the inventor owns unless hired to invent, and the Iowa Supreme Court tests invention-assignment provisions under its restrictive-covenant reasonableness standard.",
      "state": "Iowa",
      "lastReviewed": "2026-07-02",
      "license": "CC BY 4.0",
      "authors": [
        "steven-obiajulu"
      ],
      "summary": {
        "bottomLine": "Iowa has no employee-invention-assignment statute, so an assignment clause is bounded only by ordinary contract law, the common-law inventor-owns default, and the reasonableness limits Iowa applies to restraints arising from employment — not a California-style own-time carve-out or notice requirement; absent a written assignment the inventor owns unless hired to invent, and the Iowa Supreme Court tests invention-assignment provisions under its restrictive-covenant reasonableness standard, though no Iowa decision found in our review adjudicates a clause assigning inventions first conceived after employment ends.",
        "keyLaw": "No Iowa invention-assignment statute; Bandag, Inc. v. Morenings, 146 N.W.2d 916 (Iowa 1966); Revere Transducers, Inc. v. Deere & Co., 595 N.W.2d 751 (Iowa 1999)",
        "statutoryCarveOut": "none",
        "defaultOwnership": "employee",
        "employeeNoticeRequired": "n/a",
        "holdoverClauseLimit": "reasonablenessOnly",
        "carveOutScope": "Iowa has no statutory own-time carve-out; the reach of an assignment clause is limited only by ordinary contract law, the common-law inventor-owns default (subject to the hired-to-invent exception), and the restrictive-covenant reasonableness test the Iowa Supreme Court has applied to invention-assignment provisions."
      },
      "about": [
        "Iowa invention assignment",
        "Iowa no invention-assignment statute",
        "Iowa employee invention ownership",
        "Bandag Inc. v. Morenings",
        "Revere Transducers Inc. v. Deere & Co.",
        "Iowa hired to invent",
        "Iowa holdover trailing assignment"
      ],
      "translations": [
        {
          "language": "中文",
          "status": "planned"
        },
        {
          "language": "Español",
          "status": "planned"
        },
        {
          "language": "Português",
          "status": "planned"
        },
        {
          "language": "Deutsch",
          "status": "planned"
        }
      ],
      "relatedForm": {
        "slug": "openagreements-confidentiality-invention-assignment-agreement"
      }
    },
    "questions": [
      {
        "slug": "statutory-carve-out",
        "label": "Can the employer require assignment of every invention?",
        "heading": "Can an Iowa employer require assignment of every invention?",
        "answerText": "There is no statutory ceiling. Unlike California or New York, Iowa has no employee-invention-assignment statute — nothing that voids an assignment of a true own-time, own-resource invention — so an assignment clause's reach is bounded by ordinary contract law, the common-law inventor-owns default, and the reasonableness limits Iowa applies to restraints arising from employment. The Iowa Supreme Court has said that the enforceability of assignment-of-rights agreements turns on reasonableness, and the baseline that contract law operates against is that rights in an invention belong to the inventor.",
        "sources": [
          {
            "id": "revere-reasonableness-governs",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Revere Transducers, Inc. v. Deere & Co.",
            "citation": "Revere Transducers, Inc. v. Deere & Co., 595 N.W.2d 751 (Iowa 1999).",
            "url": "https://www.courtlistener.com/opinion/1989929/revere-transducers-inc-v-deere-co/",
            "deepLink": "https://www.courtlistener.com/opinion/1989929/revere-transducers-inc-v-deere-co/#:~:text=The%20determining%20factor%20of%20whether,to%20be%20one%20of%20reasonableness.",
            "proposition": "Revere Transducers, Inc. v. Deere & Co. holds that the enforceability of an employee assignment-of-rights agreement turns on reasonableness — so in Iowa the ceiling on an assignment clause is the restrictive-covenant reasonableness inquiry, not a statutory carve-out.",
            "verbatimQuote": "The determining factor of whether assignment-of-rights-agreements are enforceable seems to be one of reasonableness.",
            "date": "1999-06-03",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/iowa#src-revere-reasonableness-governs"
          },
          {
            "id": "stanford-baseline",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Systems",
            "citation": "Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Sys., Inc., 563 U.S. 776 (2011).",
            "url": "https://www.courtlistener.com/opinion/218133/board-of-trustees-of-the-leland-stanford-junior-university-v-roche/",
            "deepLink": "https://www.courtlistener.com/opinion/218133/board-of-trustees-of-the-leland-stanford-junior-university-v-roche/#:~:text=Since%201790%2C%20the%20patent%20law,invention%20belong%20to%20the%20inventor.",
            "proposition": "Stanford v. Roche confirms the long-standing premise of U.S. patent law that rights in an invention belong to the inventor, the baseline against which any assignment clause is measured.",
            "verbatimQuote": "Since 1790, the patent law has operated on the premise that rights in an invention belong to the inventor.",
            "date": "2011-06-06",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/iowa#src-stanford-baseline"
          }
        ]
      },
      {
        "slug": "employee-notice",
        "label": "Must the employer give the employee written notice of the carve-out?",
        "heading": "Must an Iowa employer notify the employee?",
        "answerText": "Not applicable. Because Iowa has no invention-assignment statute, there is no statutory carve-out to notify the employee about and no notice requirement of the kind California imposes under Labor Code § 2872 or Washington imposes under RCW 49.44.140(3). What Iowa enforces instead is contractual: disclosure and assignment duties arise from the terms of the agreement itself, and the Iowa Supreme Court has upheld such provisions as reasonable contract terms.",
        "sources": [
          {
            "id": "revere-provision-upheld",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Revere Transducers, Inc. v. Deere & Co.",
            "citation": "Revere Transducers, Inc. v. Deere & Co., 595 N.W.2d 751 (Iowa 1999).",
            "url": "https://www.courtlistener.com/opinion/1989929/revere-transducers-inc-v-deere-co/",
            "deepLink": "https://www.courtlistener.com/opinion/1989929/revere-transducers-inc-v-deere-co/#:~:text=We%20further%20conclude%20that%20the,provision%20is%20reasonable%20and%20enforceable.",
            "proposition": "Revere Transducers, Inc. v. Deere & Co. upheld an employee invention-assignment provision as reasonable and enforceable, showing that Iowa disclosure and assignment duties are creatures of contract tested for reasonableness rather than statutory obligations with notice formalities.",
            "verbatimQuote": "We further conclude that the invention assignment provision is reasonable and enforceable.",
            "date": "1999-06-03",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/iowa#src-revere-provision-upheld"
          }
        ]
      },
      {
        "slug": "default-ownership",
        "label": "Absent a written assignment, who owns the invention?",
        "heading": "Who owns an invention by default in Iowa?",
        "answerText": "The inventor, unless hired to invent. Iowa adopted the common-law inventor-owns default in Bandag, Inc. v. Morenings: absent an express or implied agreement, an invention and the patent secured for it belong to the employee who conceived it, even if it was made during employment and relates to the employer's business. The narrow exception is the employee hired to invent, whose resulting invention the employer may claim.",
        "sources": [
          {
            "id": "bandag-reluctance",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Bandag, Inc. v. Morenings",
            "citation": "Bandag, Inc. v. Morenings, 259 Iowa 998, 146 N.W.2d 916 (1966).",
            "url": "https://www.courtlistener.com/opinion/2224289/bandag-incorporated-v-morenings/",
            "deepLink": "https://www.courtlistener.com/opinion/2224289/bandag-incorporated-v-morenings/#:~:text=Courts%20are%20reluctant%20to%20infer,of%20the%20act%20of%20invention.",
            "proposition": "Bandag, Inc. v. Morenings states that courts are reluctant to infer or imply an agreement by an employee to assign patents to the employer, so an Iowa employer needs an express assignment rather than an implied one.",
            "verbatimQuote": "Courts are reluctant to infer or imply an agreement by an employee to assign patents to the employer due to a recognition of the peculiar nature of the act of invention.",
            "date": "1966-12-13",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/iowa#src-bandag-reluctance"
          },
          {
            "id": "bandag-inventor-default",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Bandag, Inc. v. Morenings",
            "citation": "Bandag, Inc. v. Morenings, 259 Iowa 998, 146 N.W.2d 916 (1966).",
            "url": "https://www.courtlistener.com/opinion/2224289/bandag-incorporated-v-morenings/",
            "deepLink": "https://www.courtlistener.com/opinion/2224289/bandag-incorporated-v-morenings/#:~:text=In%20the%20absence%20of%20special,which%20the%20inventor%20was%20employed.",
            "proposition": "Bandag, Inc. v. Morenings, quoting Williston on Contracts, adopts the rule that absent special agreement an invention and the patent secured for it belong to the inventor, even when the invention was made during employment and relates to the work the inventor was employed to do.",
            "verbatimQuote": "In the absence of special agreement to the contrary, an invention and a patent secured for it belong to the inventor, even though the invention was made during the period of his employment, and the invention relates to the matter in which the inventor was employed.",
            "date": "1966-12-13",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/iowa#src-bandag-inventor-default"
          },
          {
            "id": "stanford-inventor",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Systems",
            "citation": "Bd. of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Sys., Inc., 563 U.S. 776 (2011).",
            "url": "https://www.courtlistener.com/opinion/218133/board-of-trustees-of-the-leland-stanford-junior-university-v-roche/",
            "deepLink": "https://www.courtlistener.com/opinion/218133/board-of-trustees-of-the-leland-stanford-junior-university-v-roche/#:~:text=Since%201790%2C%20the%20patent%20law,invention%20belong%20to%20the%20inventor.",
            "proposition": "Stanford v. Roche confirms the long-standing premise of U.S. patent law that rights in an invention belong to the inventor.",
            "verbatimQuote": "Since 1790, the patent law has operated on the premise that rights in an invention belong to the inventor.",
            "date": "2011-06-06",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/iowa#src-stanford-inventor"
          },
          {
            "id": "dubilier-hired-to-invent",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "United States v. Dubilier Condenser Corp.",
            "citation": "United States v. Dubilier Condenser Corp., 289 U.S. 178 (1933).",
            "url": "https://www.courtlistener.com/opinion/1087847/united-states-v-dubilier-condenser-corp/",
            "deepLink": "https://www.courtlistener.com/opinion/1087847/united-states-v-dubilier-condenser-corp/#:~:text=One%20employed%20to%20make%20an,his%20employer%20any%20patent%20obtained.",
            "proposition": "United States v. Dubilier Condenser Corp. holds that an employee hired to make an invention who succeeds during the term of service is bound to assign the resulting patent to the employer.",
            "verbatimQuote": "One employed to make an invention, who succeeds, during his term of service, in accomplishing that task, is bound to assign to his employer any patent obtained.",
            "date": "1933-05-08",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/iowa#src-dubilier-hired-to-invent"
          }
        ]
      },
      {
        "slug": "holdover-clause-limit",
        "label": "Are post-employment trailing-assignment clauses enforceable?",
        "heading": "Are trailing-assignment (holdover) clauses enforceable in Iowa?",
        "answerText": "Reasonableness is the only limit. There is no statutory temporal cap because there is no invention-assignment statute at all, and the Iowa Supreme Court has applied its restrictive-covenant reasonableness test directly to an employee invention-assignment agreement — upholding provisions that included a one-year post-termination nondisclosure of inventions. But the clause upheld assigned inventions made during employment; no Iowa decision found in our review adjudicates a true holdover clause assigning inventions first conceived after employment ends.",
        "sources": [
          {
            "id": "revere-assignment-reasonableness",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Revere Transducers, Inc. v. Deere & Co.",
            "citation": "Revere Transducers, Inc. v. Deere & Co., 595 N.W.2d 751 (Iowa 1999).",
            "url": "https://www.courtlistener.com/opinion/1989929/revere-transducers-inc-v-deere-co/",
            "deepLink": "https://www.courtlistener.com/opinion/1989929/revere-transducers-inc-v-deere-co/#:~:text=The%20determining%20factor%20of%20whether,to%20be%20one%20of%20reasonableness.",
            "proposition": "Revere Transducers, Inc. v. Deere & Co. holds that the enforceability of an employee assignment-of-rights agreement turns on reasonableness, extending Iowa's restrictive-covenant framework to invention-assignment provisions — the framework a holdover clause would face.",
            "verbatimQuote": "The determining factor of whether assignment-of-rights-agreements are enforceable seems to be one of reasonableness.",
            "date": "1999-06-03",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/iowa#src-revere-assignment-reasonableness"
          },
          {
            "id": "revere-three-prong",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Revere Transducers, Inc. v. Deere & Co.",
            "citation": "Revere Transducers, Inc. v. Deere & Co., 595 N.W.2d 751 (Iowa 1999).",
            "url": "https://www.courtlistener.com/opinion/1989929/revere-transducers-inc-v-deere-co/",
            "deepLink": "https://www.courtlistener.com/opinion/1989929/revere-transducers-inc-v-deere-co/#:~:text=(1)%20Is%20the%20restriction%20reasonably,prejudicial%20to%20the%20public%20interest%3F",
            "proposition": "Revere Transducers, Inc. v. Deere & Co. recites Iowa's established three-prong restrictive-covenant reasonableness test and applies it to employee invention-assignment and nondisclosure provisions.",
            "verbatimQuote": "(1) Is the restriction reasonably necessary for the protection of the employer’s business; (2) is it unreasonably restrictive of the employee’s rights; and (3) is it prejudicial to the public interest?",
            "date": "1999-06-03",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/iowa#src-revere-three-prong"
          },
          {
            "id": "iowa-glass-skill-knowledge",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Iowa Glass Depot, Inc. v. Jindrich",
            "citation": "Iowa Glass Depot, Inc. v. Jindrich, 338 N.W.2d 376 (Iowa 1983).",
            "url": "https://www.courtlistener.com/opinion/2223795/iowa-glass-depot-inc-v-jindrich/",
            "deepLink": "https://www.courtlistener.com/opinion/2223795/iowa-glass-depot-inc-v-jindrich/#:~:text=An%20employee%20cannot%20be%20precluded,instruction%20while%20in%20the%20employment.",
            "proposition": "Iowa Glass Depot, Inc. v. Jindrich states Iowa's public-policy ceiling on employment restraints — an employee cannot be precluded from exercising the skill and general knowledge acquired during the employment — which bounds any overbroad assignment or holdover clause.",
            "verbatimQuote": "An employee cannot be precluded from exercising the skill and general knowledge he has acquired or increased through experience or even instruction while in the employment.",
            "date": "1983-09-21",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/iowa#src-iowa-glass-skill-knowledge"
          },
          {
            "id": "revere-hereby-assign",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Revere Transducers, Inc. v. Deere & Co.",
            "citation": "Revere Transducers, Inc. v. Deere & Co., 595 N.W.2d 751 (Iowa 1999).",
            "url": "https://www.courtlistener.com/opinion/1989929/revere-transducers-inc-v-deere-co/",
            "deepLink": "https://www.courtlistener.com/opinion/1989929/revere-transducers-inc-v-deere-co/#:~:text=I%20hereby%20assign%20all%20of,and%20discoveries%20to%20the%20Company",
            "proposition": "The employee agreement upheld in Revere Transducers, Inc. v. Deere & Co. used present-tense assignment language — quoted in the opinion — making it a clean Iowa example of a present assignment that transfers title automatically rather than promising a future assignment.",
            "verbatimQuote": "I hereby assign all of my right, title, and interest in and to such inventions and discoveries to the Company",
            "date": "1999-06-03",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/iowa#src-revere-hereby-assign"
          },
          {
            "id": "bandag-inventor-default-practice",
            "authorityType": "case-law",
            "tier": "primary-source-backed",
            "title": "Bandag, Inc. v. Morenings",
            "citation": "Bandag, Inc. v. Morenings, 259 Iowa 998, 146 N.W.2d 916 (1966).",
            "url": "https://www.courtlistener.com/opinion/2224289/bandag-incorporated-v-morenings/",
            "deepLink": "https://www.courtlistener.com/opinion/2224289/bandag-incorporated-v-morenings/#:~:text=In%20the%20absence%20of%20special,which%20the%20inventor%20was%20employed.",
            "proposition": "Bandag, Inc. v. Morenings, quoting Williston on Contracts, adopts the rule that absent special agreement an invention and the patent secured for it belong to the inventor, even when the invention was made during employment and relates to the work the inventor was employed to do.",
            "verbatimQuote": "In the absence of special agreement to the contrary, an invention and a patent secured for it belong to the inventor, even though the invention was made during the period of his employment, and the invention relates to the matter in which the inventor was employed.",
            "date": "1966-12-13",
            "anchor": "https://openagreements.org/practice-guides/invention-assignment/us/iowa#src-bandag-inventor-default-practice"
          }
        ]
      }
    ]
  }
}