Justia Iowa Supreme Court Opinion Summaries

The Supreme Court reversed in part the judgment of the court of appeals affirming the district court's dismissal of the medical malpractice action brought by the Estate of Roberta Butterfield against Chautauqua Guest Home, Inc., a nursing home, holding that the Estate was not required to serve a certificate of merit affidavit on Chautauqua in this case.While the Estate brought its action it did not serve a certificate of merit on Chautauqua. Chautauqua filed a motion to dismiss the claims against it with prejudice under Iowa Code 147.140. The district court granted the motion, and the court of appeals affirmed the dismissal of the Estate's claims. The Supreme Court reversed in part, holding (1) the certificate of merit requirement set forth in section 147.140 does not apply to plaintiffs who need experts solely for causation, as opposed to the standard of care or breach; and (2) remand was required to establish which of the Estate's claims survived the failure to file the certificate of merit. View "Estate of Butterfield v. Chautauqua Guest Home, Inc." on Justia Law

The Supreme Court reversed the order of the district court granting summary judgment for Defendants in this medical malpractice action, holding that a plaintiff who files a noncompliant certificate of merit and then voluntarily dismisses the case need not rely on the certificate filed in the first case when bringing a second action.Plaintiffs timely filed a certificate of merit affidavit in their medical malpractice action but voluntarily dismissed the case when Defendants challenged the qualifications of the expert witness that signed the affidavit. Thereafter, Plaintiffs refiled their case, providing a certificate of merit affidavit signed by a different expert witness. Defendants moved for summary judgment on the basis that the certificate of merit in the first case was deficient. The district court granted the motion to dismiss. The Supreme Court reversed and remanded the case, holding that Defendants were not entitled to dismissal of their case with prejudice. View "Kirlin v. Monaster" on Justia Law

In this medical malpractice case the Supreme Court reversed the order of the district court vacating Plaintiff's prior voluntary dismissal of her action without prejudice and dismissing the case with prejudice, holding that the district court lacked jurisdiction to rule on Defendant's motion to dismiss.Plaintiff filed a medical negligence suit against Defendant. When Plaintiff failed to file a certificate of merit affidavit Defendant moved to dismiss her petition with prejudice. That same day, Plaintiff voluntarily dismissed her petition under Iowa R. Civ. P. 1.943. The district court subsequently granted Defendant's motion to dismiss, dismissing Plaintiff's claims with prejudice. On appeal, Plaintiff argued that her voluntary dismissal terminated the case. The Supreme Court agreed, holding that Plaintiff's voluntary dismissal was self-executing and ended the case, and therefore, the district court lacked jurisdiction to rule on Defendant's motion to dismiss. View "Ronnfeldt v. Shelby County Chris A. Myrtue Memorial Hospital" on Justia Law

The Supreme Court affirmed the district court's grant of summary judgment for Defendants in this medical malpractice action, holding that Defendants were not estopped from asserting the statute of repose defense, which applied to the facts of this case.In 2004, a benign cyst was detected on Linda Berry's right kidney. In 2009, Dr. Paul Grossman treated Berry for colitis, and a radiologist noted that the mass had grown in size, but no one mentioned this to Berry. In 2016, Berry was treated for renal cancer. Berry died from cancer in 2019. In 2018, Berry filed a medical malpractice action against Defendants for failing to disclose the kidney mass in 2009. Defendants moved for summary judgment based on the six-year statute of repose found in Iowa Code 614.1(9). The district court granted summary judgment for Defendants, rejecting Plaintiffs' reliance on the doctrine of fraudulent concealment to avoid the six-year bar. The court of appeals reversed. The Supreme Court reversed, holding that Berry could not rely on fraudulent concealment to estop Defendants from asserting the six-year statute of repose as a defense to Berry's claims. View "Downing v. Grossman" on Justia Law

The Supreme Court reversed the judgment of the district court entered after the jury returned a no-negligence verdict in favor of a surgeon in this medical malpractice case, holding that the district court erred in ruling on permissible expert opinions, and the error was not harmless.A patient who suffered a disabling stroke after undergoing surgery to relieve stenosis brought a medical malpractice suit against the surgeon. At trial, the patient was allowed to introduce evidence that a neurologist and neuroradiologist, from whom he sought a second opinion following surgery, had read his CT angiogram as showing a lesser degree of stenosis. Other evidence, however, was excluded. The Supreme Court reversed the no-negligence judgment in favor of the surgeon, holding (1) the district court misapplied the pretrial disclosure requirements of Iowa Code 668.11 and Iowa R. Civ. P. 1.500(2); and (2) the error was harmful. View "McGrew v. Otoadese" on Justia Law

The Supreme Court dismissed this appeal from a jury verdict in favor of Defendants in this medical malpractice action, holding that Plaintiff failed to timely file her notice of appeal.Plaintiff, individually and on behalf of her minor son, brought this lawsuit alleging that her son developed severe, disabling injuries from bacterial meningitis and that Defendants were liable for medical negligence and parental loss of consortium. The jury returned a verdict in favor of Defendants. Plaintiff appealed, presenting several issues. The Supreme Court dismissed the appeal, holding that the appeal was untimely and should be dismissed under Iowa R. App. P. 6.101(1)(b). View "Valles v. Mueting" on Justia Law

The Supreme Court affirmed the decision of the district court granting Defendants' motion for summary judgment and dismissing Plaintiff's claims for negligent misrepresentation, fraudulent misrepresentation, and breach of contract, holding that Plaintiff's claims were subject to the two-year statute of limitations set forth in Iowa Code 614.1(9) and were untimely.On Defendants' motion for summary judgment, the district court held that Plaintiff's causes of action arose out of patient care and were barred by section 614.1(9), the two-year statute of limitations governing malpractice action. The Supreme Court affirmed, holding that each of Plaintiff's allegations originated from representations regarding patient care and the patient care Defendants provided, and therefore, Plaintiff's claims were untimely under section 614.1(9). View "Kostoglanis v. Yates" on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment for Defendants on Plaintiffs' medical malpractice claims, holding that Plaintiffs failed to set forth specific facts showing a prima facie case of causation and lost chance of survival.Sharon Susie lost her right arm and eight of her toes due to a disorder known as necrotizing fasciitis. Sharon and her husband (together, Plaintiffs) filed a negligence claim against Defendants seeking damages for the amputation of Sharon's arm and other injuries. Plaintiffs alleged that Defendants were negligent because Sharon's condition was not properly diagnosed and treatment was not timely commenced and that Defendants' actions resulted in the lost chance to save Sharon's arm and toes from amputation. The district court granted summary judgment for Defendants. The Supreme Court affirmed, holding that summary judgment was properly granted because Plaintiffs failed to set forth specific facts showing a prima facie case of causation and lost chance of survival. View "Susie v. Family Health Care of Siouxland, P.L.C." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the ruling of the district court denying Plaintiff’s motion for a new trial after the jury returned a unanimous verdict finding that Defendant was not negligent, holding that Plaintiff was not prejudiced by the district court’s failure to respond in the affirmative to a certain jury question.Plaintiff suffered a disabling stroke while confined in a halfway house. Plaintiff sued both the halfway house and an attending emergency room physician at a nearby hospital. Plaintiff settled with the halfway house before trial, and the case proceeded to trial against the physician. During deliberations, the jury asked, “If we attribute 25% fault to [the physician] and 75% to [the halfway house] would [the plaintiff] only get 25% since [the halfway house] has been released?” The district court answered by directing the jury back to the original instructions, which did not explain the effect of any fault allocation. The jury returned a verdict finding Defendant not negligent. On appeal, Plaintiff argued that the district court should have answered “yes” to the jury’s question. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court probably should have given an affirmative answer but that there was no prejudice. View "Mumm v. Jennie Edmundson Memorial Hospital" on Justia Law

In this medical malpractice action, the Supreme Court affirmed in part and reversed and remanded in part the judgment of the district court removing Plaintiffs’ informed consent claims from this case and entering judgment for Defendants on Plaintiffs’ specific negligence claim.Plaintiffs, a patient and his family, brought this lawsuit against Defendants, a physician and the physician’s employer. The district court granted summary judgment in favor of Defendants on the informed consent claim based on the physician’s failure to disclose his lack of training and experience in performing the procedure and, during trial, refused to allow the informed consent claim based on the physician’s failure to disclose the risk of the surgery considering the patient’s bad heart. The jury then returned a verdict for Defendants on the specific negligence claim. The court of appeals affirmed. The Supreme Court affirmed the judgment on the specific negligence claim but remanded the case to allow Plaintiffs to proceed on their two informed consent claims, holding that the district court erred in removing the two informed consent claims from the case. View "Andersen v. Khanna" on Justia Law