What Qualifies as an Agricultural Building in Iowa?
For Iowa landowners and developers, understanding when abuilding or property is exempt from local zoning laws is key to avoiding costly delays, permit disputes, or enforcement issues. While Iowa law protects many agricultural structures from zoning oversight, the exemption is not automatic—and recent case law shows just how nuanced these rules can be.
Under Iowa Code § 335.2, zoning ordinances “shall not apply to land, farm houses, farm barns, farm outbuildings or other buildings or structures which are primarily adapted, by reason of nature and area, for use for agricultural purposes.” This protection applies even if the agricultural use is part of a broader set of operations. However, no exemption applies to structures located in floodplains, which remain fully subject to local zoning and development regulations.
Further reinforcing this exemption, Iowa Code §331.304(3)(b) confirms that county building codes do not apply to farmhouses or other farm buildings used for agricultural purposes. Similarly, Iowa Code § 18B.2 excludes agricultural buildings from the definition of “development” in state land use planning laws—again, provided they are not situated on floodplain land.
The key legal question, then, is what it means for a structure—or land—to be “primarily adapted for agricultural purposes.”
Defining “Primarily Adapted for Agricultural Purposes”
In the landmark case Kuehl v. Cass County, 555 N.W.2d686 (Iowa 1996), the Iowa Supreme Court examined whether a proposed hog confinement facility qualified for the zoning exemption. The Court ruled that agricultural exemption status hinges on the functional aspects of the buildings or structures, whether existing or planned, and their intended use for agricultural activity, such as raising livestock or harvesting crops.
The Court emphasized that a property’s use, not merely its location or appearance, determines whether it qualifies for protection under § 335.2. Even structures under construction can qualify, provided their intended use aligns with farming operations.
Importantly, the Court clarified that the people working the land do not need to be classified as agricultural workers under the Fair Labor Standards Act for the exemption to apply. The focus is on land use—not job titles.
Farmhouses vs. Residences: Navigating the Gray Areas
One of the most complex areas of Iowa’s zoning exemption laws involves residences on agricultural land. Not every home on a rural parcel qualifies as a “farmhouse.”
In Lang v. Linn County Board of Adjustment, 829N.W.2d 1 (Iowa 2013), the Iowa Supreme Court evaluated whether two homes on the same property—one owner-occupied and one tenant-occupied—were exempt. The court affirmed that the owner’s home qualified because it was connected to active farming operations. But it denied the exemption for the rented home, concluding there was insufficient evidence the tenants were engaged in meaningful agricultural activity.
The case highlighted several key criteria for evaluating whether a house is “primarily adapted” for agriculture:
- The scale and scope of farming activity occurring on or near the residence,
- The relationship between the residents and those operations, and
- The proportionality of the home’s use to the surrounding agricultural land (e.g., a farmhouse cannot be justified solely by a backyard tomato patch).
The Court also referenced the Iowa Attorney General’s opinion that residents do not need to derive their primary income from farming, but there must still be a meaningful and functional connection between the residence and agricultural activity on the land.
Applying the “Underlying Realities” Test
The Lang decision reinforced a practical “realities test” for zoning boards and developers: when evaluating if a building or land qualifies for the exemption, decision-makers must look beyond technicalities and assess the real-world use and character of the property.
For example, simply reclassifying land or subdividing parcels won’t shield a residential building from zoning oversight if the structure isn’t truly integrated into agricultural use. As the Court noted, allowing such loopholes would open the door to sidestepping zoning ordinances by assigning superficial farm tasks to residents of otherwise non-agricultural homes.
Takeaways for Iowa Landowners and Developers
Iowa law offers important protections for agricultural buildings—but those protections are not blanket exemptions. Before starting construction or purchasing rural land for development, it’s critical to consider:
✅ Whether the building or land is functionally used for agriculture,
✅If the structure is located outside of a designated floodplain,
✅How any associated residences are integrated into the agricultural operation, and
✅Whether local authorities are likely to challenge the claimed exemption.
The LDM Agribusiness Team has deep experience helping landowners, farmers, and developers navigate Iowa’s complex zoning and land use regulations. Whether you're expanding a farm operation, investing in rural property, or planning agricultural construction, we can help you protect your rights and avoid regulatory missteps.
To learn more, contact our Agribusiness Team or visit our Agricultural Law page.
