Justia Iowa Supreme Court Opinion Summaries

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

A woman underwent knee replacement surgery at a hospital and soon developed respiratory distress. Shortly after the operation, she allegedly suffered a femur fracture in a fall while hospitalized, which her doctor failed to detect on an X-ray. The following day, she fell again, reportedly because a nurse fell on her while assisting her, resulting in a more severe fracture. This severe injury caused fat emboli to enter her bloodstream and led to a pulmonary embolism. She was transferred to another hospital, where her deteriorating condition was documented. She died nearly two weeks later. Her estate filed a wrongful-death lawsuit alleging that the defendants’ negligence in failing to diagnose and prevent the fracture ultimately caused her death.The Iowa District Court for Polk County granted summary judgment for the defendants, dismissing the lawsuit as untimely under Iowa Code § 614.1(9)(a), which imposes a two-year statute of limitations on medical malpractice actions. The district court determined that the estate knew or should have known of the injury and its cause by February 5, 2021, the date the decedent was transferred and her injury was documented. Because the estate filed its petition on February 17, 2023, more than two years later, the court found the claims time-barred.Reviewing the case, the Supreme Court of Iowa affirmed the district court’s decision. The Supreme Court held that, under Iowa law, wrongful-death claims based on medical malpractice are derivative of the decedent’s personal injury claims. When the injury and its negligent cause are known during the decedent’s lifetime, the limitations period begins at that time, not the date of death. Because the estate had knowledge of the injury and its cause by February 5, 2021, the wrongful-death action was untimely and barred by the statute of limitations. View "Cataldo v. RCHP-Ottumwa, LLC" on Justia Law

A woman died after a rapid health decline while receiving emergency and critical care at a West Des Moines hospital. Her husband, who was appointed as the administrator of her estate, filed a wrongful-death medical malpractice lawsuit against various medical providers. He brought the suit both on behalf of the estate and in his individual capacity, alleging multiple claims including negligence and seeking damages for emotional and financial loss. The husband, a nonlawyer, filed the petition without legal counsel and argued that, as the sole beneficiary, he should be allowed to proceed pro se or, alternatively, be given time to retain an attorney if one was required.The Iowa District Court for Polk County dismissed the lawsuit, ruling that the petition was a legal nullity because a nonlawyer cannot represent an estate or other parties in court, and denied the husband’s request for more time to secure counsel. The court also denied his motion to amend the petition. On appeal, the Iowa Court of Appeals affirmed the dismissal, agreeing that the wrongful-death action could not proceed without a lawyer and finding that the request for additional time had not been properly preserved for appeal. Two appellate judges dissented, concluding the husband was entitled to a warning and additional time to obtain counsel.The Supreme Court of Iowa granted further review. The court held that a nonlawyer cannot represent an estate or other persons in a wrongful-death action in district court. However, it found that the district court abused its discretion by not granting the husband reasonable time to retain counsel before dismissing the case. The Supreme Court vacated the court of appeals’ decision, reversed the district court’s judgment, and remanded the case with instructions to allow at least thirty days for the husband to secure trial counsel. View "Estate of Tornell v. Trinity Health Corporation" on Justia Law

An employee at a quarry died after falling through an unsecured catwalk gate into dangerous machinery. The machinery, used for processing lime, was typically secured by metal linchpins, but at the time of the accident, the gate was fastened only with a metal wire instead of the pins. The worker’s family brought suit against two of his co-employees, a supervisor and a safety director, alleging gross negligence for failing to prevent the accident. Both defendants testified that they did not know the securing pins were missing, and there had been no prior similar accidents since safety rails were installed decades earlier.After a jury trial in the Iowa District Court for Benton County, the plaintiffs were awarded damages totaling approximately $2.84 million. The district court denied the defendants’ post-trial motions. On appeal, the Iowa Court of Appeals affirmed, reasoning that the evidence supported the conclusion that injury was probable under the circumstances, and relied in part on what the defendants should have known.The Supreme Court of Iowa reviewed the case and determined that, under Iowa law, recovery for co-employee gross negligence requires proof that the defendants had actual knowledge of the specific peril—the missing pins that left the gate unsecured. The court found that there was no evidence either defendant actually knew about the missing pins or unsecured gate. As a result, the legal standard for gross negligence was not met. The Supreme Court of Iowa vacated the decision of the court of appeals, reversed the judgment of the district court, and remanded the case for dismissal, holding that the plaintiffs’ exclusive remedy was under the state’s workers’ compensation statute. View "Griffith v. Kulper" on Justia Law

Several residents of Estherville, Iowa, sued a former police officer, the police chief, the City of Estherville, and its insurance company, alleging that the officer repeatedly accessed and disseminated their confidential criminal history and intelligence data for improper purposes between 2015 and his resignation on May 3, 2019. The officer used this data for personal gain, including assisting with vehicle repossessions and harassing certain plaintiffs. Complaints about his conduct were made to the police chief, who ultimately placed the officer on administrative leave and accepted his resignation. Criminal charges were later brought against the officer in 2022 for his actions.After learning of the wrongful data access between 2021 and 2022, the plaintiffs filed suit on July 7, 2023, in the Iowa District Court for Emmet County, asserting statutory and common law claims, including invasion of privacy and conspiracy, and seeking damages under Iowa Code section 692.6. The defendants moved to dismiss, arguing the two-year statute of limitations under the Iowa Municipal Tort Claims Act (IMTCA) barred the claims, since all alleged misconduct ended by May 3, 2019. The district court denied dismissal, holding that the statutory claim under section 692.6 was subject to a five-year limitation with a discovery rule, and that the remaining claims accrued when plaintiffs discovered the wrongdoing.On appeal, the Iowa Court of Appeals reversed the district court and ordered dismissal, concluding that all claims were governed by the IMTCA’s two-year statute of limitations and that the date of injury was when the data was accessed or disseminated, not when plaintiffs learned of it. The Iowa Supreme Court affirmed the appellate court, holding that the IMTCA’s statute of limitations applied to all claims and began at the time of the wrongful acts, regardless of later discovery or emotional harm. The case was remanded for dismissal. View "Abrahamson v. Scheevel" on Justia Law

Jack Rose was a resident at Oakland Manor, a skilled nursing facility in Iowa. During the COVID-19 pandemic, Rose was hospitalized and later returned to the facility, where he was placed in precautionary isolation following public health guidance. After attending off-site medical appointments, he was again isolated but was subsequently hospitalized for a suspected stroke and tested positive for COVID-19. Rose died in the hospital, with COVID-19 listed as the immediate cause of death. A federal inspection later found Oakland Manor had failed to fully comply with recommended infection-control protocols, including inconsistent use of personal protective equipment and incomplete isolation measures.The plaintiffs, Rose’s sons, brought wrongful death and other related claims against Oakland Manor, alleging reckless and willful misconduct in failing to follow federal and state COVID-19 prevention guidelines. The Iowa District Court for Pottawattamie County granted summary judgment in favor of Oakland Manor, holding that the plaintiffs' evidence—primarily a federal inspection report and an expert witness disclosure—did not establish reckless or willful misconduct as required to overcome statutory immunity provided to health care providers for COVID-19-related injuries. The plaintiffs appealed, and the Iowa Court of Appeals affirmed the dismissal, finding insufficient evidence of recklessness and, in addition, lack of qualified evidence regarding causation.The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment, concluding that the plaintiffs had not presented sufficient evidence to create a genuine issue of material fact regarding recklessness or willful misconduct under Iowa Code section 686D.6(2). The Court vacated the portion of the Court of Appeals decision related to causation, holding that the deficiencies at Oakland Manor amounted at most to negligence, not recklessness, and thus statutory immunity applied. View "Rose v. Oakland Healthcare Management, LLC" on Justia Law