Justia Iowa Supreme Court Opinion Summaries

Cynthia Miles, a sixty-four-year-old woman suffering from acute psychosis and a history of suicidal ideation, experienced several psychiatric crises in 2021. After multiple hospitalizations and escapes from care facilities, she was admitted to Harbor Point, an unlocked mental health facility, where she again escaped on November 11, 2021. Despite a search, Miles was never found. Her family, having previously experienced her disappearances followed by safe returns, could not determine her fate. After extensive efforts to locate her failed, her family petitioned the Iowa District Court for Pottawattamie County for a judicial determination of death. Following a jury trial, the court issued a certificate of presumed death on August 29, 2022.Subsequently, Miles’s daughter, as administrator of her estate, filed a wrongful death lawsuit against several healthcare providers. The defendants asserted that the action was time-barred under Iowa’s two-year statute of limitations for wrongful death claims, arguing that the limitations period began either at Miles’s disappearance or when the family first sought a declaration of death. The Iowa District Court for Cass County rejected this argument, ruling that the statute of limitations began only upon the judicial declaration of death, not the earlier disappearance.The Iowa Supreme Court reviewed the interlocutory appeal to determine when the limitations period commenced. The court held that, in a case where there is no known physical injury and it is unclear whether the missing person is alive or dead, the statute of limitations for a wrongful death claim does not begin to run until there is a judicial determination of death. The court affirmed the district court’s ruling, allowing the wrongful death action to proceed as timely filed. View "Schneide v. Holliday" on Justia Law

A patient suffered an injury during knee surgery in March 2022 and, together with his wife, filed a medical malpractice lawsuit against the operating surgeon and the orthopedic clinic in January 2023. Iowa law requires medical malpractice plaintiffs to serve a certificate of merit affidavit within sixty days after the defendant’s answer to the lawsuit. The plaintiffs served a certificate of merit within the deadline. However, the document was not sworn before an authorized officer and did not include the phrase “penalty of perjury” as required by Iowa statutes. Over a year later, the plaintiffs served an amended certificate that met the affidavit requirements, but it was well past the statutory deadline.After the defendants answered and discovery proceeded for more than a year, the defendants moved to dismiss in the Iowa District Court for Polk County, arguing that the timely certificate did not comply with statutory requirements. The district court found that the initial certificate was neither a true affidavit nor a permissible substitute under the relevant statutes. The court also concluded that the late-filed, proper affidavit could not cure the statutory violation because it was not filed within the required sixty days and there was no extension by agreement or motion. The district court dismissed the case.The Iowa Supreme Court reviewed the appeal. It held that substantial compliance with the certificate of merit affidavit requirement means providing either a true affidavit executed before an authorized person or a statement under penalty of perjury within sixty days. The plaintiffs failed to do either within the deadline, and their later submission could not cure the defect. The court also rejected arguments that the defendants had waived the affidavit requirement or that the statutory scheme violated the Iowa Constitution. The decision of the district court was affirmed. View "Rarick v. Smidt" on Justia Law

After a woman was injured in a car accident and treated at a hospital, an X-ray suggested a lung nodule, and her medical records recommended a chest CT scan for further investigation. No CT scan was ordered or performed, and she was released. Almost two years later, after suffering a femur fracture, a CT scan at a different hospital revealed cancer, and she subsequently passed away. Her husband and children, representing themselves and her estate, brought a wrongful-death medical malpractice suit against the hospital and multiple providers, alleging failure to properly follow up on the lung nodule.In the Iowa District Court for Scott County, the plaintiffs timely served certificates of merit as required by Iowa Code section 147.140, but these certificates were neither notarized nor included a statement that they were signed under penalty of perjury. Following the Iowa Supreme Court’s decision in Miller v. Catholic Health Initiatives-Iowa, Corp., the defendants moved to dismiss, arguing the certificates did not satisfy statutory requirements. The plaintiffs resisted, providing new expert statements but maintaining these were not amendments. The district court granted the defendants’ motion to dismiss with prejudice. After the death of one of the original plaintiffs, his son was appointed as executor and administrator for the estates. Notices of appeal were filed, initially signed by the non-lawyer administrator.The Supreme Court of Iowa first determined that the estates’ appeal should not be dismissed due to the unauthorized practice of law in filing the notice of appeal, since counsel promptly appeared and continued representation. On the substantive issue, the court was evenly divided on whether the district court correctly dismissed the suit for noncompliance with section 147.140. As a result, the dismissal was affirmed by operation of law. The motion to dismiss the appeal was denied, but the district court judgment was affirmed. View "Willhoite v. Genesis Health System" on Justia Law

A patient was admitted to a hospital with acute pancreatitis and later transferred to the critical care unit, where he received continuous dialysis through a catheter. A nurse on his care team failed to properly secure the dialysis tubing and fastened it to the bedrail without adequate slack. When the patient was repositioned, the catheter was pulled from his neck, leading to air entering the line and causing cardiac arrest. The patient’s wife, who was present, later filed a lawsuit as executor of his estate, alleging that the nurse was negligent and that the hospital was both vicariously liable for the nurse’s actions and directly negligent in retaining her, given her involvement in a previous patient death. The wife also sought damages for her own emotional distress as a bystander and requested punitive damages.The Iowa District Court for Polk County denied the hospital’s motion for summary judgment on the claims for negligent retention, bystander emotional distress, and punitive damages. The district court held that Iowa law allowed a negligent retention claim even where the employer had stipulated to vicarious liability for the employee’s conduct, found that there was a triable issue as to whether the wife contemporaneously perceived the negligent event for emotional distress damages, and concluded that punitive damages could not be ruled out as a matter of law.The Iowa Supreme Court reversed the district court’s denial of summary judgment and remanded the case. The court held that when an employer does not dispute vicarious liability for an employee’s conduct, claims for negligent hiring, retention, or supervision are precluded. The court also held that the wife’s claim for bystander emotional distress failed as a matter of law because she did not contemporaneously perceive the injury-producing event. Finally, the court concluded there was insufficient evidence for punitive damages against the hospital or the nurse. View "Baldwin v. Central Iowa Hospital Corp." on Justia Law

A resident of a skilled nursing facility signed an arbitration agreement upon admission. Twelve days later, the resident died. The resident’s husband, acting both individually and as executor of her estate, brought suit in Iowa District Court for Henry County against the nursing facility and several related entities, as well as additional healthcare providers. He alleged negligence, gross negligence, wrongful death, and dependent adult abuse. Nearly a year into the litigation, the nursing facility defendants moved to compel arbitration based on the agreement signed by the decedent.The Iowa District Court for Henry County granted the motion to compel arbitration. The court reasoned that, under the existing Iowa precedent, waiver of the right to arbitrate requires both conduct inconsistent with that right and prejudice to the opposing party—a two-part test established in prior Iowa Supreme Court cases. Applying this standard, the district court found limited prejudice to the plaintiff because discovery had not been extensive and the trial date was still far off. The plaintiff was granted interlocutory appeal.The Supreme Court of Iowa reviewed the case for correction of errors at law. The court determined that the Federal Arbitration Act (FAA) governed because the agreement involved interstate commerce, and that the FAA preempts Iowa's arbitration-specific waiver rule, which requires a showing of prejudice. Instead, the court held that the generally applicable contract law standard for waiver applies: the voluntary or intentional relinquishment of a known right. Applying this standard, the Supreme Court of Iowa concluded that the nursing facility had impliedly waived its contractual right to arbitration by participating in litigation and discovery for months after being aware of the arbitration agreement, and by delaying a motion to compel arbitration. The Supreme Court of Iowa reversed the district court’s order and remanded the case for further proceedings. View "Cole v. Southeast Iowa Orthopaedics and Sports Medicine" on Justia Law

An employee of a plumbing subcontractor was injured when a trench collapsed at a residential construction site, resulting in serious physical and emotional harm. The employee had been directed by his supervisor to enter a trench that did not comply with OSHA safety regulations. The general contractor for the project was not present at the site and only learned of the accident months later, after an OSHA investigation. The subcontractor, not the general contractor, was responsible for the trenching work and the day-to-day safety of its employees.After receiving workers’ compensation and settling gross negligence claims against his co-employees, the injured worker proceeded to trial solely on a negligence claim against the general contractor. The Iowa District Court for Polk County denied the general contractor’s motions for directed verdict and judgment notwithstanding the verdict, allowing the case to go to a jury, which found the general contractor liable and awarded substantial compensatory and punitive damages.The Supreme Court of Iowa reviewed the case and reversed the district court’s decision. The court held that, as a general rule, a general contractor does not owe a duty of care to the employees of an independent contractor. The court found that neither the “retained control” nor “peculiar risk” exceptions to this rule applied. The general contractor did not retain operative control over the subcontractor’s work, either by contract or by conduct, and residential trenching work is not inherently or peculiarly dangerous as a matter of law under Iowa precedent. Accordingly, the Supreme Court of Iowa held that the general contractor was entitled to judgment notwithstanding the verdict and reversed the lower court’s ruling. View "Kono v. D.R. Horton, Inc." on Justia Law

A patient underwent surgery on September 4, 2020, and died twelve days later. Her estate and children brought a medical malpractice suit against the surgeon and hospital, alleging negligence. The defendants sought dismissal, arguing the plaintiffs had not satisfied Iowa’s certificate of merit requirements under Iowa Code section 147.140(1), which mandates a supporting expert affidavit early in medical malpractice litigation. The district court denied the motion to dismiss.The defendants then sought interlocutory review from the Iowa Supreme Court. The Iowa Supreme Court reversed the district court’s denial, finding the plaintiffs had not complied with the statutory affidavit requirement, and remanded with instructions to dismiss the case with prejudice. Following the remand, the plaintiffs attempted to file dismissals without prejudice before and after the district court’s order of dismissal with prejudice. Despite these filings, the district court entered a dismissal with prejudice as directed by the Iowa Supreme Court. The plaintiffs then filed a new lawsuit asserting the same claims against the same defendants. The defendants moved to dismiss this second action, citing claim preclusion (res judicata) and the statute of limitations. The Iowa District Court for Clinton County dismissed the second action.On appeal, the Iowa Supreme Court affirmed the dismissal. The court held that its prior mandate required dismissal with prejudice, and any attempt by the plaintiffs to dismiss without prejudice was contrary to that mandate and thus ineffective. The court found that the elements of claim preclusion were satisfied: the parties and claims were identical to the prior action, and there was a final judgment on the merits. Accordingly, the second lawsuit was barred. The Iowa Supreme Court affirmed the district court’s dismissal on claim preclusion grounds. View "Shontz v. Mercy Medical Center-Clinton, Inc." on Justia Law

During a period of foggy weather near Anamosa, Iowa, Margaret McQuillen was driving southbound on Highway 151 when her vehicle collided with a semitrailer operated by Clifford Takes, who was employed by West Side Transport, Inc. Takes made an unprotected left turn across Margaret’s lane, resulting in a severe underride collision that caused Margaret catastrophic injuries, including traumatic brain injuries and numerous fractures. The state patrol cited Takes for failing to yield, and he pleaded guilty. Margaret’s parents, acting as her guardians, filed suit against Takes and West Side, alleging negligence and vicarious liability.The Iowa District Court for Linn County tried the case. The jury found both parties negligent, assigning 73% of the fault to Takes and West Side, and 27% to Margaret. Margaret’s damages were assessed at over $35 million, leading to a judgment in her favor for approximately $26 million after comparative fault reduction. The defendants’ motions for a new trial and for judgment notwithstanding the verdict were denied.The Iowa Supreme Court reviewed the case after the defendants appealed, arguing errors in the plaintiffs’ closing arguments warranted a new trial, and the plaintiffs moved to dismiss the appeal, claiming a settlement had rendered the appeal moot. The court denied the motion to dismiss, concluding the parties had not reached a full settlement disposing of the appeal. On the merits, the court found no abuse of discretion by the district court in its handling of closing arguments, finding that the arguments did not warrant a mistrial or new trial, and that any improper argument did not likely affect the trial’s outcome. The court also concluded the defendants had not preserved error regarding arguments about present value. The judgment of the district court was affirmed. View "McQuillen v. West Side Transport, Inc." on Justia Law

Jenna Sondag underwent hip surgery performed by Dr. John Hoffman at Orthopaedic Specialists, P.C. in February 2017. She filed a medical malpractice action in January 2019, agreeing to designate expert witnesses by a deadline set under Iowa Code section 668.11. Sondag missed this deadline due to a combination of her attorneys’ involvement in a lengthy trial, a medical emergency affecting one attorney, and a calendaring error by their docketing software. The defendants moved for summary judgment based on the missed deadline, while Sondag sought an extension to name her expert witnesses.The Iowa District Court for Scott County held a hearing on both motions, and in 2019, found good cause for Sondag’s delay due to the circumstances described. The court denied summary judgment and extended the expert designation deadline. The defendants did not seek interlocutory appeal at that time. Nearly four years later, days before trial, the district court revisited its prior order after the defendants filed a motion in limine to decertify Sondag’s expert. The court reversed its earlier finding, excluded the expert, and dismissed the case for failure to timely designate an expert witness.Sondag appealed, and the Iowa Court of Appeals affirmed the dismissal, siding with the district court’s 2023 decision. The Supreme Court of Iowa granted further review. The Supreme Court held that while a district court may correct an erroneous ruling before final judgment, its 2019 order extending the deadline was not an abuse of discretion, but its 2023 order excluding the expert and dismissing the case was an abuse of discretion. The court vacated the decision of the court of appeals, reversed the district court’s judgment, and remanded the case for trial. View "Sondag v. Orthopaedic Speciatists, P.C." on Justia Law

The plaintiff underwent a total hysterectomy and bilateral salpingo-oophorectomy, performed by a board-certified obstetrician-gynecologist at a medical center. Subsequently, she experienced symptoms that led to the discovery of a ureteral injury requiring surgical repair at a different facility. She alleged that the defendants were negligent in both the performance of the surgery and the postoperative care. To support her claims, she designated a board-certified urologist as her expert witness to opine on the applicable standard of care and alleged breach.After the expert’s deposition, the defendants moved to strike his testimony, arguing that he was not qualified under Iowa Code section 147.139 because he was not board-certified in the same or a substantially similar specialty as the defendant physician. The Iowa District Court for Polk County agreed, concluding that urology was not substantially similar to obstetrics and gynecology, and therefore the plaintiff’s expert was not qualified to testify about the standard of care or breach. Lacking a qualified expert, the district court also granted summary judgment for the defendants, effectively dismissing the case.On appeal, the Supreme Court of Iowa reviewed whether the district court erred in its application of the statutory requirements for expert qualification. The court held that, while both physicians were licensed to practice medicine, the statute required that, where the defendant is board-certified, the plaintiff’s expert must also be board-certified in the same or a substantially similar specialty. The court concluded that urology and obstetrics/gynecology are not substantially similar specialties. As a result, the Supreme Court of Iowa affirmed the district court’s decision to strike the expert and grant summary judgment for the defendants. View "Jones v. Lindell" on Justia Law