An action heretofore cognizable only after another has been prosecuted to conclusion may be joined with the latter; and the court shall grant relief according to the substantive rights of the parties. But there shall be no joinder of an action against an indemnitor or insurer with one against the indemnified party, unless a statute so provides.
Rule 1.237.Dependent remedies joined
Division II: Actions, Joinder of Actions and Parties · Last amended February 15, 2002 · Last verified July 15, 2026
In one sentenceRule 1.237 lets an action that once could only be brought after another action concluded now be joined with that other action, but it bars joining a claim against an indemnitor or insurer with the claim against the indemnified party unless a statute allows it.
Full Text of Rule 1.237
Plain-English Summary
Some claims historically could not be brought until another, related action had already reached its conclusion — a dependent remedy waiting on the outcome of a prior proceeding. Rule 1.237 lets that dependent action be joined with the underlying action instead of waiting for separate, sequential litigation. Once joined, the court grants relief according to the substantive rights of the parties, rather than treating the joined claim as an afterthought to be resolved on different terms.
The rule draws one clear line, however. It bars joining an action against an indemnitor or an insurer with an action against the party who is indemnified, unless a statute specifically provides for that joinder. This keeps the underlying liability dispute against the indemnified party separate from the coverage or indemnity dispute, absent a statute directing otherwise, presumably to avoid complications like exposing the existence of insurance coverage to a jury deciding the underlying liability question.
Frequently Asked Questions
Can I join a claim that used to require waiting for another lawsuit to finish first?
Yes. Rule 1.237 lets an action formerly cognizable only after another was prosecuted to conclusion be joined with that other action, with the court granting relief according to the parties' substantive rights.
Can I sue an insurer in the same action as the party it insures?
Generally, no. Rule 1.237 bars joinder of an action against an indemnitor or insurer with an action against the indemnified party, unless a statute provides for it.
Why does Rule 1.237 separate indemnity or insurance claims from the underlying liability claim?
The rule itself does not state its reasoning, but keeping those claims apart, absent a statute allowing joinder, avoids combining the question of the indemnified party's liability with a separate dispute over coverage or indemnification.
Does a statute ever allow joining an insurer with the insured party in one action?
Yes. Rule 1.237's bar applies unless a statute so provides, meaning a specific statutory provision can permit that joinder where it would otherwise be barred.
What does the court do once a formerly dependent action is properly joined under this rule?
Rule 1.237 directs the court to grant relief according to the substantive rights of the parties in the joined action.
Source & verification. Rule text and the Comment are
reproduced verbatim from the Iowa Rules of Civil Procedure, adopted by the
Iowa Supreme Court. Last verified July 15, 2026.
· Official source
Also known as: iowa joining dependent remedy actionssuing insurer with insured party iowaindemnitor joinder bar iowa lawsuitdependent claim joined with main action iowa