DES MOINES — A horrific accident involving a team of horses, a horse-drawn sickle mower and a falling steel bar left an Iowa woman permanently paralyzed from the waist down. But the Iowa Supreme Court has ruled the man operating the horses cannot be held liable under the circumstances, finding that Iowa law specifically protects people involved in certain domesticated-animal activities from lawsuits stemming from the unpredictable behavior of animals.
The case, Janey Shafer v. Frank Santana, was decided June 12, 2026, and centered on Iowa’s Domesticated Animal Activities Act.
According to court records, Frank Santana was operating a horse-drawn sickle mower on his property while Janey Shafer recorded video of the activity.
After Santana finished mowing, he asked Shafer to hold the horses while he attempted to secure the mower’s sickle bar.
Then everything went wrong.
The sickle bar fell to the ground and startled the horses. As the animals moved, Shafer fell, was struck by one of the mower’s steel wheels and was dragged.
She suffered catastrophic injuries that left her permanently paralyzed from the waist down.
Shafer sued Santana, arguing that he should be held responsible for her injuries.
Santana countered that he was protected by Iowa Code Chapter 673, commonly known as the Domesticated Animal Activities Act, which limits liability for injuries caused by risks inherent in activities involving certain domesticated animals.
A district court sided with Santana and dismissed the case through summary judgment.
The Iowa Court of Appeals later concluded that the law did apply to the situation but found there was enough of a question about whether Santana acted recklessly to allow that issue to proceed toward trial.
The Iowa Supreme Court ultimately disagreed.
The high court vacated the Court of Appeals ruling and reinstated the district court’s decision in Santana’s favor.
At the heart of the dispute was an unusual legal question: Was Santana still “driving” the horses when the team was temporarily stopped?
The Supreme Court said yes.
The justices determined that “driving” horses is not limited to the moments when the animals are physically moving. Instead, the term encompasses the broader process of controlling horses harnessed to a nonmotorized vehicle.
Because the horses remained hitched to the sickle mower and Santana intended to continue operating them, the court concluded that the activity remained covered by Iowa’s domesticated-animal liability law.
That determination was critical.
Iowa law recognizes that animals can react unpredictably to sudden movement, noises, unfamiliar circumstances and other stimuli. The Supreme Court concluded that the horses becoming startled when the sickle bar fell was precisely the type of inherent risk lawmakers intended the statute to cover.
Shafer also argued that Santana’s actions were reckless, which could have removed the legal immunity.
Her case included expert testimony criticizing how Santana operated the mower, handled the horses, maintained equipment and followed safety procedures.
But the Supreme Court drew a sharp distinction between negligence and recklessness.
The justices concluded that even if Santana could arguably have taken greater precautions, there was not enough evidence showing he knowingly disregarded a serious danger or engaged in conduct that made severe injury highly probable.
At most, the court found, the evidence could support an allegation of negligence — not the substantially higher legal standard of recklessness required to overcome the statutory immunity.
The result is a significant ruling for Iowa farmers, horse owners and others who participate in activities involving livestock and domesticated animals.
The decision reinforces that Iowa’s liability protections can extend beyond recreational horseback riding and similar activities to traditional agricultural work involving draft animals and equipment.
It also underscores how difficult it can be for an injured person to overcome statutory immunity simply by arguing that additional safety precautions could have prevented an accident.
For Shafer, the consequences were life-changing.
But legally, Iowa’s highest court concluded that the tragedy resulted from the kind of unpredictable animal reaction the Legislature specifically chose to protect against liability — and that the evidence did not rise to the level necessary to prove Santana acted recklessly.
The ruling leaves the district court’s dismissal of Shafer’s lawsuit intact.