Justia Iowa Supreme Court Opinion Summaries

Fatima Belhak experienced complications during childbirth, leading Dr. Denice Smith to perform an episiotomy. Post-delivery, Belhak suffered from pain and infection due to a misdiagnosed fourth-degree laceration, which required delayed reconstructive surgery. Belhak and her husband sued Smith and her employer, Women’s Care Specialists, P.C., for negligence.The Iowa District Court for Scott County held a jury trial, which resulted in a verdict favoring Belhak, awarding her $3.25 million in damages. Smith moved for a new trial, citing insufficient evidence and misconduct by Belhak’s lawyer during closing arguments. The district court denied the motion. Smith appealed, and the Iowa Court of Appeals reversed the jury verdict, finding insufficient evidence to support one of the negligence claims.The Iowa Supreme Court reviewed the case and vacated the Court of Appeals decision, affirming the district court’s judgment. The Supreme Court found that the district court did not abuse its discretion in denying a new trial based on alleged misconduct by Belhak’s lawyer. The court also held that sufficient evidence supported the jury’s finding that Smith’s use of 4-0 sutures, which were too weak, caused the wound to break down, leading to infection and delayed surgery. The court concluded that the jury could reasonably infer causation from the expert testimony provided. View "Belhak v. Smith" on Justia Law

Douglas Wilson underwent hip replacement surgery at Shenandoah Medical Center (SMC) and was injured in a fall while recovering. He and his wife sued the hospital for professional negligence in his postoperative care. They identified a nursing expert but failed to certify this expert by the agreed deadline. The certification was only made three months later, after SMC moved for summary judgment. The plaintiffs argued that expert testimony was not required and blamed defense counsel’s silence for missing the deadline.The Iowa District Court for Page County found good cause for the delay, citing defense counsel’s silence and ongoing scheduling negotiations. The court did not decide whether expert testimony was necessary. SMC appealed, and the Iowa Court of Appeals affirmed the district court’s decision, with a dissenting opinion arguing that the plaintiffs had not shown good cause.The Iowa Supreme Court reviewed the case and concluded that the district court abused its discretion in finding good cause for the plaintiffs’ delay. The court held that defense counsel is not obligated to remind opposing counsel of expert certification deadlines and that an adversary’s silence cannot excuse missing the statutory deadline by three months. The court emphasized that the plaintiffs’ three-month delay was a serious deviation and that the lack of prejudice to the defendant alone was insufficient to establish good cause.The Iowa Supreme Court vacated the decision of the Court of Appeals, reversed the district court’s judgment, and remanded the case for the district court to determine whether the plaintiffs’ claims require expert testimony to avoid summary judgment. View "Wilson v. Shenandoah Medical Center" on Justia Law

Jahn Patric Kirlin and Sara Louise Kirlin filed a medical malpractice lawsuit against Dr. Christian William Jones, Dr. Barclay A. Monaster, and Physicians Clinic Inc. d/b/a Methodist Physicians Clinic – Council Bluffs. Jahn Kirlin experienced severe neck pain and headaches, and despite seeking medical help, an MRI was delayed. Dr. Monaster, who had returned from treatment for alcohol abuse, refused to order an MRI, and Kirlin later suffered a stroke after a chiropractic adjustment. The plaintiffs allege that the defendants altered medical records and that Dr. Monaster was intoxicated during treatment.The Pottawattamie County District Court initially dismissed the case due to a defective certificate of merit. The plaintiffs refiled with a new certificate, but the court granted summary judgment for the defendants. The Iowa Supreme Court reversed this decision, allowing the plaintiffs to proceed.Upon remand, the district court did not set new deadlines, leading to confusion about the applicable expert certification deadline. The defendants moved for summary judgment again, arguing the plaintiffs missed the deadline. The district court agreed, finding no good cause to extend the deadline, and granted summary judgment to the defendants.The Iowa Supreme Court reviewed the case and found that the district court abused its discretion by not finding good cause for the plaintiffs' delayed expert certification. The court noted the confusion about deadlines, lack of prejudice to the defendants, the plaintiffs' diligence, and the defendants' actions. The court reversed the summary judgment and remanded the case for further proceedings. View "Kirlin v. Monaster" on Justia Law

Marlene Banwart and her husband Richard filed a medical malpractice lawsuit in 2020 against Neurosurgery of North Iowa, P.C., Dr. David Beck, and Dr. Thomas Getta. Marlene had undergone a lumbar laminectomy performed by Dr. Beck in July 2018, followed by severe postoperative pain and complications, including an epidural hematoma that required emergency surgery. The plaintiffs alleged negligence in the surgery and postoperative care by Dr. Beck and Dr. Getta.The Iowa District Court for Cerro Gordo County ruled on cross-motions for summary judgment. The court dismissed the plaintiffs' action as time-barred, concluding that the Iowa Supreme Court's emergency supervisory orders tolling the statute of limitations during the COVID-19 pandemic were invalid. However, the court found that the plaintiffs had substantially complied with Iowa's certificate of merit affidavit statute, despite the certificates not being signed under oath or penalty of perjury. Both parties appealed these rulings.The Iowa Supreme Court reviewed the case and bypassed the statute of limitations issue, focusing on the cross-appeal regarding the certificate of merit. The court held that the plaintiffs' certificates did not substantially comply with Iowa Code section 147.140 because they were not signed under oath or penalty of perjury. The court also rejected the plaintiffs' claims that the statute was void for vagueness and that the defendants had waived their rights by delaying their challenge. Consequently, the court reversed the district court's ruling on the certificates of merit and remanded the case for entry of summary judgment in favor of the defendants. View "Banwart v. Neurosurgery of North Iowa, P.C." on Justia Law

A baby, S.K., was injured during labor and delivery, allegedly due to the negligence of the delivering doctor, Dr. Goodman, who used a Mityvac obstetrical vacuum delivery system. The plaintiff, S.K.'s conservator, claimed that the use of the vacuum caused brain damage to S.K. and sought damages from Dr. Goodman’s employer, Obstetric & Gynecologic Associates of Iowa City and Coralville, P.C. (the clinic).A jury in the Iowa District Court for Johnson County found in favor of the plaintiff, awarding substantial damages. The clinic appealed, arguing that the district court erred in admitting a package insert from the vacuum, which contained hearsay statements about when the vacuum should not be used and potential harms from its use. The clinic contended that the insert's admission violated Iowa’s hearsay rule and prejudiced the trial's outcome.The Iowa Supreme Court reviewed the case and agreed with the clinic. The court found that the package insert contained hearsay and did not fit within any recognized exceptions, including the residual exception and the market reports exception. The court noted that the insert's admission was prejudicial, as it directly addressed a central dispute in the case and was emphasized in the plaintiff's closing argument. The court concluded that the erroneous admission of the insert deprived the clinic of a fair trial.The Iowa Supreme Court reversed the district court's judgment and remanded the case for a new trial. The court also addressed a procedural issue raised by the clinic regarding the plaintiff's certificate of merit affidavit, ultimately denying the clinic's motion to reverse on those grounds. View "S.K. v. Obstetric & Gynecologic Associates of Iowa City and Coralville, P.C." on Justia Law

The case revolves around a medical malpractice claim filed by Darrin P. Miller against Catholic Health Initiatives-Iowa, Corp. and several medical professionals. The claim arose from the death of Miller's wife, Meredith, who died after a car accident when an endotracheal tube was incorrectly placed in her esophagus instead of her trachea. Miller alleged that the medical providers breached the standard of care by incorrectly performing the intubation and failing to identify and correct the error.The defendants sought dismissal of the case on two grounds: the expert's certificate of merit was not signed under oath as required by Iowa Code section 147.140, and the expert, an anesthesiologist, was not qualified to testify against the defendant surgeons or respiratory therapist. The district court denied the defendants' motions, ruling that the expert's unsworn but signed letter substantially complied with the affidavit requirement and that the expert's qualifications satisfied section 147.139.The Supreme Court of Iowa reversed the district court's decision. The court held that the expert's signed but unsworn report did not substantially comply with section 147.140's affidavit requirement, and this violation was not cured by the expert's sworn declaration served over three months after the statutory deadline. The court did not reach the question of whether the expert anesthesiologist was qualified under section 147.139 to testify against these defendants. The case was remanded for dismissal of the medical malpractice claims with prejudice. View "Miller v. Catholic Health Initiatives-Iowa, Corp." on Justia Law

In Iowa, a ten-year-old boy was treated at the University of Iowa Hospitals and Clinics (UIHC) for a dislodged feeding tube and died the next day. The boy's mother filed administrative tort claims on behalf of the child's estate prior to being appointed as the estate's administrator. The child's parents also individually claimed loss of consortium. The claims were dismissed by the district court, which ruled that the mother lacked authority to file a claim on behalf of the estate prior to her official appointment, and that the parents had not properly filed individual administrative tort claims.The Supreme Court of Iowa held that the district court was correct to dismiss the parents' individual claims as no individual administrative tort claims were filed. However, the court determined the district court had erred in dismissing the estate's claims, arguing that the mother's administrative tort claims were valid despite her not being appointed as the estate's administrator at the time of filing. The court explained that a representative may act to protect an estate's interests before being officially appointed and can ratify pre-appointment acts, granting them the same effect as acts that would occur after appointment. The court also confirmed that the district court did not abuse its discretion by refusing to permit the plaintiffs' new evidence. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "Anderson v. State of Iowa" on Justia Law

In this case, Charlene and Michael Jorgensen sued Dr. Adam Smith, his professional corporation (Adam Smith, M.D., P.C.), and Tri-State Specialists, L.L.P., a clinic that employed Dr. Smith, after Charlene underwent surgeries in 2016 and 2018 that they allege were botched by Dr. Smith. They specifically claim that Tri-State was negligent in retaining Dr. Smith despite knowledge of his unfitness to practice surgery. The Supreme Court of Iowa considered whether the Jorgensens were required to produce a "certificate of merit affidavit" containing an expert’s opinion that the clinic had breached the applicable standard of care by retaining Dr. Smith, under Iowa Code section 147.140 (2018). The court found that this requirement did not apply to the Jorgensens' claim of negligent retention. While Tri-State is considered a "health care provider" as per the definition in the Iowa Code, the language of the statute requiring a certificate of merit refers to negligence in the practice of a profession, occupation, or in patient care. The court concluded that in the context of section 147.140, the term "occupation" does not encompass the activities of entities such as Tri-State. Therefore, the court affirmed the lower court's decision denying Tri-State's motion for summary judgment. View "Jorgensen v. Smith" on Justia Law

In the case before the Supreme Court of Iowa, the plaintiff, Renee Hummel, brought a medical malpractice suit against the defendants, Adam B. Smith, Adam Smith, M.D., P.C., and Tri-State Specialists, L.L.P. The defendants requested an interlocutory review of a lower court order that denied their motion to strike and for summary judgment. The issue at the heart of the defendants' motion was that the expert who signed the plaintiff's certificate of merit did not have an active license to practice medicine.The Supreme Court of Iowa reversed the lower court's decision and remanded the case. The court determined that an expert who signs a plaintiff's certificate of merit in a medical malpractice case must have an active license to practice medicine. Therefore, the lower court erred in denying the defendants' motion to strike and for summary judgment on the basis that the plaintiff's certificate of merit was signed by an expert without an active medical license. View "Hummel v. Smith" on Justia Law

In the Supreme Court of Iowa, the appellants, the estate and family of Deanna Dee Fahrmann, had filed a wrongful-death action against ABCM Corporation and two of its employees, alleging nursing home malpractice. The appellants failed to serve a certificate of merit affidavit, required under Iowa Code section 147.140, signed by a qualified expert within sixty days of the defendants’ response to the claim. Instead, they served initial disclosures, signed only by their counsel, that named their expert within the statutory sixty-day deadline. After the deadline, the defendants moved to dismiss the case for noncompliance, and the appellants served a certificate signed by their expert and argued that they substantially complied with the statute. The district court dismissed the case based on the mandatory language of the statute.On appeal, the Supreme Court of Iowa affirmed the lower court's decision to dismiss the case. The court held that the plaintiffs' initial disclosure, signed only by their counsel, did not comply with or substantially comply with the certificate of merit requirement under section 147.140 of the Iowa Code. The law unambiguously required the plaintiffs to timely serve a certificate of merit affidavit signed under oath by a qualified expert stating the expert’s familiarity with the applicable standard of care and its breach by the defendants unless the parties extend the deadline by agreement or the plaintiffs show good cause to move for an extension within the sixty-day deadline. The plaintiffs' untimely service of a certificate signed by their expert did not constitute substantial compliance with the statute. Therefore, dismissal was mandatory under the plain language of the statute. View "The Estate of Deanna Dee Fahrmann v. ABCM Corporation" on Justia Law