
The State of Iowa is appealing a district court decision that refused to dismiss negligence claims stemming from a 2015 training accident.
Katherine Avenarius, a Dubuque police officer training to become a firearms instructor, signed a liability waiver before attending the Iowa Law Enforcement Academy’s two-week course at Camp Dodge. On the first day, while drawing her weapon during a drill, she accidentally shot herself in the leg.
She later sued the state, claiming negligence by the instructor and the academy. The state sought summary judgment, arguing the signed waiver—titled “WAIVER RELEASE FROM LIABILITY AND ASSUMPTION OF RISK AGREEMENT”—clearly barred such claims by releasing the state from “any and all claims” for injuries during training.
The district court denied the motion, ruling the waiver did not clearly cover the state’s own negligence. Iowa now asks the Supreme Court to reverse, citing prior cases upholding similar broad releases and arguing the waiver’s prominent title and language provided sufficient notice.
A decision could clarify the enforceability of exculpatory clauses in law-enforcement training programs.

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