Justia Iowa Supreme Court Opinion Summaries

Articles Posted in Medical Malpractice
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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

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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

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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

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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

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Parents of a child born with severe disabilities may bring a wrongful birth claim based on the physicians’ failure to inform them of prenatal test results showing a congenital defect that would have led them to terminate the pregnancy.Plaintiff filed suit against several medical defendants, alleging that the doctors negligently failed to accurately interpret, diagnose, and respond to fetal abnormalities in her ultrasound and that, as a result of this negligent care, Plaintiff gave birth to a child with severe brain abnormalities. The district court granted Defendants’ motion for summary judgment on the grounds that Iowa has not recognized “wrongful birth” as a cause of action. On appeal, Defendants alleged that a wrongful birth claim is a new cause of action unsupported by Iowa law. Plaintiffs, in turn, noted a clear majority of other jurisdictions allow parents to sue under these facts. The Supreme Court held that wrongful birth fits within common law tort principles governing medical negligence claims, and no public policy or statute precludes the cause of action. The Supreme Court thus reversed the district court’s grant of summary judgment for Defendants, holding that wrongful birth is a cognizable claim under Iowa law. View "Plowman v. Fort Madison Community Hospital" on Justia Law

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Dennis Willard was seriously injured in a motor vehicle accident. Defendant was treated at the University of Iowa Hospitals and Clinics (UIHC). Willard claimed that while undergoing an abdominal CT scan, UIHC was negligent in its handling of him. After the CT scan, a UIHC employee filed a Patient Safety Net (PSN) form about the incident. Willard filed a medical negligence lawsuit against the State and requested discovery of the PSN and related documents. The State objected to the disclosure of the materials on the grounds they were privileged. The district court granted Willard’s motion to compel and ordered the State to produce the documents. The Supreme Court reversed, holding that the PSN and related documents were privileged under the mobility and mortality statute and were therefore not subject to discovery. Remanded. View "Willard v. State" on Justia Law

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Plaintiff, individually, and on behalf of her children, sued two physicians for medical malpractice. During the ensuing trial, one of the jurors fainted while she was sitting in her chair in the jury box. One of the defendant physicians immediately rose to assist the juror, after which the juror recovered and was excused. Plaintiffs moved for a mistrial, which the trial court denied. The jury subsequently returned verdicts for the physicians. The court of appeals reversed and ordered a new trial as to both physicians. The physician who did not help the ailing juror sought further review. The Supreme Court reversed the court of appeals as to the appellant, holding that the district court did not abuse its discretion when it allowed the jury verdict to stand as to the physician who had not rendered medical assistance because nothing in that physician’s behavior during the incident could have “engendered any particular good will in her favor.” Remanded. View "Jack v. Booth" on Justia Law

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Larysa and Alan Asher filed an action individually and as parents and next friends of their minor child, asserting that Dr. Anthony Onuigbo was negligent in delivering their baby. The jury found in favor of Asher and awarded damages. Onuigbo appealed. The Supreme Court affirmed, holding (1) the district court erred by providing the jury with a causation instruction based upon the Restatement (Second) of Torts rather than an instruction based upon the Restatement (Third) of Torts, as adopted by the Court in Thompson v. Kaszinski, but the error was harmless under the facts and circumstances of this case; and (2) substantial evidence supported submission of two challenged specifications of negligence to the jury. View "Asher v. OB-GYN Specialists, P.C." on Justia Law

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In this case, the Supreme Court was asked to review a summary judgment ruling dismissing a wrongful death action because it was commenced later than is allowed under Iowa Code 614.1(9), a statute of repose limiting the time allowed for commencing medical negligence cases. Plaintiffs contended their case should not have been dismissed because Defendants fraudulently concealed the fact that a tissue specimen harvested from Plaintiffs' decedent more than six years before the filing of this action was not evaluated by a board-certified pathologist. In the alternative, Plaintiff contended the continuum-of-negligent-treatment doctrine precluded the summary dismissal of this case notwithstanding the statute of repose. The Supreme Court affirmed, holding (1) section 614.1(9) in this case operated to extinguish the decedent's cause of action even before she and her husband knew it had accrued; and (2) under the the circumstances, the fraudulent-concealment doctrine and the continuum-of-negligent-treatment doctrine did not preserve Plaintiffs' causes of action, and section 614.1(9) denied Plaintiffs a remedy for negligent acts or omissions occurring more than six years prior to the commencement of this action. View "Estate of Anderson v. Iowa Dermatology Clinic, PLC" on Justia Law

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Plaintiffs sued a surgeon, alleging negligent performance of a pancreaticoduodenectomy, and a hospital, contending it negligently granted credentials to the surgeon. The district court entered judgment in favor of Defendants after concluding that the tort of negligent credentialing was a viable claim in Iowa. Plaintiffs appealed, contending the district court applied the wrong standard of care in adjudicating Plaintiffs' claim of negligent credentialing against the hospital. The Supreme Court affirmed, holding (1) the district court applied the standard of care advocated by Plaintiffs; and (2) substantial evidence supported the district court's conclusion that the hospital did not breach the standard of care. View "Hall v. Jennie Edmundson Memorial Hosp." on Justia Law