Hansen v. Savage Arms Co et al: See Order at [32] dismissing Paige Hansen, Vista Outdoor Sales, LLC and Vista Outdoor Inc when entering final judgment, No. 3:2017cv03002 - Document 75 (N.D. Iowa 2018)
Court Description: ORDER denying Plaintiff's 67 Motion to Compel Discovery and Defendants' motion for sanctions (Doc. 70 at 7-8). See text of Order. Signed by Chief Magistrate Judge CJ Williams on 3/22/2018. (skm)
Download PDF
<![CDATA[
Hansen v. Savage Arms Co et al: See Order at [32] dismissing P...or Inc when entering final judgment Doc. 75 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF IOWA CENTRAL DIVISION RONALD W. HANSEN, No. 17-CV-3002-LTS Plaintiff, ORDER vs. SAVAGE ARMS CO.; and SAVAGE ARMS INC., Defendants. ____________________ TABLE OF CONTENTS I. Factual and Procedural Background ......................................................... 2 II. Applicable Law ................................................................................. 3 III. Discussion ..................................................................................... 5 A. Bulged Barrels ................................................................................ 6 B. Muzzleloader Return Team ............................................................... 11 C. Sanctions ..................................................................................... 12 IV. Conclusion................................................................................... 13 This ’atter is bef“re the C“urt “n R“na‘d W. Hansen s ( ”‘aintiff ) M“ti“n t“ Compel Discovery and Request for Expedited Relief. (Doc. 67). Savage Arms Co.1 and 1 Savage Arms Co. has apparently been dissolved and no longer exists. (Doc. 9, at 1 n. 1 Savage Ar’s C“. is a diss“‘ved De‘aware C“r”“rati“n and is n“t a viab‘e ‘ega‘ entity. ). However, Savage Arms Co. has not been dismissed from the instant case. Thus, the Court will refer to both Savage Arms Co. and Savage Arms Inc. as the defendants in this matter. Dockets.Justia.com Savage Ar’s Inc. ( defendants ) ti’e‘y fi‘ed their resistance (D“c. 70), and ”‘aintiff timely filed his reply. (Doc. 71). Although plaintiff requested oral argument, the Court determined that oral argument was not necessary and, further, that granting ”‘aintiff s request f“r “ra‘ argu’ent w“u‘d ha’”er ”‘aintiff s request f“r ex”edited re‘ief. As such, the Court considers the motion to be fully submitted and ripe for a ruling. For the f“‘‘“wing reas“ns, ”‘aintiff s ’“ti“n is denied. Defendants request f“r sancti“ns is denied. I. FACTUAL AND PROCEDURAL BACKGROUND Plaintiff alleges that while firing a muzzleloader rifle manufactured by defendants, the muzzleloader exploded, causing plaintiff to suffer severe permanent injury to both his right hand and ear. (Doc. 8). The cause of the alleged explosion is in dispute. Plaintiff theorizes that the explosion was caused by a design defect, which caused the steel used t“ ’anufacture the firear’ t“ weaken and begin bu‘ging, bef“re u‘ti’ately exploding. (Doc. 67-3, at 2-4). Defendants, however, contend that the alleged explosion was caused by user error as opposed to a defect with the firearm. This dispute has led plaintiff to seek discovery of those firearms whose barrels bulged. Although defendants maintain that bu‘ged barre‘s are irre‘evant t“ the instant ‘itigati“n, defendants assert that in an effort to avoid discovery disputes and move this case forward, Defendant[s] produced c“”ies “f a‘‘ inf“r’ati“n ”ertaining t“ bu‘ged barre‘s that plaintiff contends has gone unproduced. (Doc. 70, at 4-6). P‘aintiff, in turn, asserts that defendants c‘ai’ that they have ”r“duced a‘‘ such ’ateria‘ is si’”‘y untrue and ’is‘eading. (D“c. 71, at 2). Plaintiff, however, offers nothing in support of this contention. This is the second motion to compel discovery that has come before the Court. In the C“urt s first Order, the C“urt deter’ined that defendants ”r“”er‘y “bjected t“ certain definitions posed by plaintiff in the context of discovery requests and that defendants 2 properly proposed different clarifying definitions. (Doc. 62, at 11-12). The Court ”revi“us‘y f“und the a‘ternative definiti“ns t“ be un“bjecti“nab‘e. (Id., at 11). As the C“urt n“ted, h“wever, the C“urt s deter’inati“n that the definitions were acceptable was due ’“re t“ ”‘aintiff s fai‘ure t“ ”r“vide the C“urt with any reas“n t“ find the a‘ternative definitions improper, than it was due to a finding on the merits of the definitions themselves. (Id., at 11-12). Otherwise stated, plaintiff previously failed to make his case that the definitions were improper. The issues currently presented largely overlap with those issues the Court considered previously. The Court has addressed the overlap where appropriate. The issues presented in the instant motion are as follows: 1) whether bulged barrels are to be included within the scope of discovery; 2) whether defendants should be c“’”e‘‘ed t“ ”r“duce any and a‘‘ inf“r’ati“n generated by the ’uzz‘e‘“ader return tea’; 3) whether defendants should be compelled t“ ”r“duce in as c“nvenient form as ”“ssib‘e the c“ntact inf“r’ati“n f“r cust“’ers wh“ returned ’uzz‘e‘“aders with bu‘ged barre‘s; 4) whether defendants sh“u‘d be c“’”e‘‘ed t“ ’ake an i’’ediate due and diligent search for the current employment, addresses[,] and phone numbers of proposed de”“nents; and 5) whether defendants sh“u‘d be “rdered t“ c“’”‘y with the C“urt s previous Order. (Doc. 62). (Doc. 67, at 1-3). Defendants c“ntend that the ’“ti“n was not substantia‘‘y justified, and request that they be awarded reas“nab‘e att“rneys fees incurred in resisting the motion. (Doc. 70, at 7-8). II. APPLICABLE LAW A ”arty ’“ving t“ c“’”e‘ disc“very ’ust inc‘ude a certificati“n that the ’“vant has in good faith conferred or attempted to confer with the person or party failing to make disc‘“sure “r disc“very in an eff“rt t“ “btain it with“ut c“urt acti“n. FED. R. CIV. P. 37(a)(1); see also LR 37(a). Alternatively, counsel may certify in a written declaration 3 that such a ”ers“na‘ c“nference was i’”“ssib‘e and describe the eff“rts undertaken t“ schedule the conference. An exchange of written communications or a single telephone ’essage wi‘‘ n“t, by itse‘f, satisfy the require’ents “f this [ru‘e]. LR 37(a). The importance of the meet-and-confer requirement is not to be diminished. See Williams v. Cent. Transp. Int’l., Inc., No. 4:13-CV-2009 (CEJ), 2014 WL 6463306, at *2 (E.D. M“. N“v. 17, 2014) ( The ’eet-and-c“nfer require’ent is n“t an e’”ty f“r’a‘ity. ). Rule 26(b)(1) of the Federal Rules of Civil Procedure provides: Unless otherwise limited by court order, the scope of discovery is as follows: Parties may obtain discovery regarding any nonprivileged matter that is relevant to any ”arty s claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the ”arties relative access to relevant information, the ”arties resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information within this scope of discovery need not be admissible in evidence to be discoverable. FED. R. CIV. P. 26(b)(1). Rule 26(b) is widely acknowledged as ‘ibera‘ in scope and interpretation, extending to those matters which are relevant and reasonably calculated to lead to the discovery of admissible evidence. Hofer v. Mack Trucks, Inc., 981 F.2d 377, 380 (8th Cir. 1992) (citation omitted). Additionally, in the context of discovery, the standard of relevance is br“ader than in the context of admissibility. Id. (citing Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340 (1978)). Yet, [s]“’e threshold showing of relevance must be made before parties are required to open wide the doors of discovery and to produce a variety of information which does not reasonably bear upon the issues in the case. Id. Rule 401 of the Federal Rules of Evidence reads: [e]vidence is relevant if: (a) it has any tendency to make a fact more or less probable than it would be without the evidence; and (b) the fact is of consequence in determining the acti“n. 4 FED. R. EVID. 401. A discovery request sh“u‘d be considered relevant if there is any possibility that the information sought may be relevant to the claim or defense of any ”arty. Catipovic v. Turley, No. C11-3074, 2013 WL 1718061, at *2 (N.D. Iowa Apr. 19, 2013) (internal quotation marks and citation omitted). The party requesting discovery bears the burden of making a threshold showing that the requested discovery would be relevant; once this threshold has been met, the burden of proving irrelevance shifts to the party resisting the motion to compel. Hofer, 981 F.2d at 380-81 (holding that the proponent of discovery bears the initial burden of establishing relevance); Cont’l Ill. Nat’l Bank & Trust Co. of Chi. v. Caton, 136 F.R.D. 682, 684-85 (D. Kan. 1991) ( A‘‘ disc“very requests are a burden “n the ”arty wh“ ’ust respond thereto. Unless the task of producing or answering is unusual, undue or extraordinary, the general rule requires the entity answering or producing the documents t“ bear that burden. (interna‘ citati“n “’itted)). Here, the Court finds that the parties did properly meet and confer regarding this discovery dispute in compliance with FED. R. CIV. P. 37(a)(1) and LR 37(a). III. DISCUSSION Having found that the meet and confer requirement has been satisfied, the Court will first consider whether bulged barrels should be included within the scope of discovery and whether defendants should be compelled to pr“duce the ‘ast kn“wn address and telephone number of all persons who returned their ’uzz‘e‘“aders due t“ bulged barrels. (Doc. 67, at 2). The Court will then turn to whether defendants should be compelled to produce any materials generated by the muzzleloader return team. Fina‘‘y, the C“urt wi‘‘ c“nsider defendants ’“ti“n f“r sancti“ns. The Court previously ordered defendants t“ su””‘e’ent their disc“very res”“nses to explicitly state that they have diligently and in good faith searched for [documents 5 res”“nsive t“ ”‘aintiff s requests f“r ”r“ducti“n] and have ”r“duced a‘‘ res”“nsive d“cu’ents [defendants] ‘“cated. (D“c. 62, at 16). This dec‘arati“n is re‘evant t“ whether defendants should be compelled to produce the materials now requested, as outlined supra, as we‘‘ as t“ ”‘aintiff s fina‘ request that defendants be “rdered t“ c“’e into compliance with this direct mandate. The Court has been advised that although defendants had not provided the aforementioned declaration as of the date the instant motion was filed, defendants have since provided the declaration. The Court previously provided that it would accept defendants dec‘arati“n as true. (Id.). The Court stands by that intention and, thus, is satisfied that defendants have fu‘‘y c“’”‘ied with the C“urt s ”revi“us Order. As a resu‘t, ”‘aintiff s request that defendants be required t“ c“’e int“ c“’”‘iance with the C“urt s ”revi“us Order (D“c. 62) is denied as moot. Likewise, the parties have indicated that defendants have provided the requested contact information for potential deponents. (D“cs. 70, at 7; 71, at 3). As such, ”‘aintiff s request that defendants be c“’”e‘‘ed t“ provide the requested contact information is denied as moot. A. Bulged Barrels The motion to compel currently at issue largely circles around the definition of “ther si’i‘ar instances defendants ”r“”“sed in res”“nse t“ ”‘aintiff s disc“very requests. P‘aintiff c“ntends that the definiti“n “f “ther si’i‘ar instances sh“u‘d inc‘ude bulged barrels because, as shown above, plaintiff asserts that a bulging barrel is indicative of a barrel that will soon explode. (Doc. 67-3, at 3-4). Thus, ”‘aintiff s ‘“gic is that bulged barrels should not be excluded from discovery simply because they had not yet reached the point of exploding. (Id.). As defendants assert, this issue has a‘ready been ‘itigated. The definiti“n “f “ther si’i‘ar instances was “ne “f the definiti“ns ”revi“us‘y sub’itted t“ the C“urt, and the 6 Court previously found the definition proposed by defendants—which did not include bu‘ged barre‘s as “ther si’i‘ar instances —was not objectionable. Plaintiff had his chance to present the Court with evidence showing why bulged barrels should be included in the definiti“n “f “ther si’i‘ar instances, and ”‘aintiff fai‘ed t“ use such evidence in support of his position. Plaintiff now relies upon an expert witness report in support of his position. (Doc. 67-7). Notably, this report is dated October 16, 2017 (Doc. 67-7, at 30), and was inc‘uded as an exhibit t“ ”‘aintiff s first ’“ti“n t“ c“’”e‘. (D“c. 40-2). The difference, however, is the purpose for which the report is now being used, as will be discussed infra. To allow a party a second opportunity to litigate an issue such as the “ne n“w ”resented resu‘ts in a waste “f judicia‘ res“urces and a waste “f the ”arties resources. See Parklane Hosiery Co., Inc. v. Shore, 439 U.S. 322, 326 (1979) ( C“‘‘atera‘ est“””e‘ . . . has the dua‘ ”ur”“se “f ”r“tecting litigants from the burden of relitigating an identical issue with the same party or his privy and of promoting judicial ec“n“’y by ”reventing need‘ess ‘itigati“n. (citati“n “’itted)). Such a waste certain‘y d“es n“t serve the interests “f secur[ing] the just, speedy, and inexpensive deter’inati“n “f cases. FED. R. CIV. P. 1. The Court will thus not permit plaintiff a second opportunity to litigate the same issues presented previously. As discussed above, the Court will not entertain ”‘aintiff s renewed request that bulged barrels be included within the scope of discovery and that defendants be compelled to produce the contact information for those customers who returned their muzzleloaders due to bulged barrels. The Court will, however, explain the rationale behind its declination to reconsider the issue. Without fully recounting its earlier discussion (Doc. 62) of whether bu‘ged barre‘s sh“u‘d be inc‘uded in the definiti“n “f “ther si’i‘ar instances, the C“urt wi‘‘ su’’ari‘y n“te the differences presented between this second motion to compel and the first. The primary difference is that plaintiff has now met his 7 burden of proof in showing why bulged barrels should be included in the definition. Plaintiff previously presented no legal analysis nor expert opinion on the issue. The primary issue presented with respect to whether bulged barrels are relevant is an issue of metallurgy.2 The Court is not learned in metallurgy, nor is this an issue that the Court could properly consider absent some sort of expert analysis. The first time plaintiff raised the issue of bulged barrels, plaintiff simply provided argument, without evidence, that bu‘ged barre‘s sh“u‘d be inc‘uded in the definiti“n “f incidents. “ther si’i‘ar Because the bu‘ged barre‘s are an issue of metallurgy, about which the Court cannot formulate its “wn findings, ”‘aintiff s argu’ent a‘“ne was insufficient t“ ’eet his burden of proving relevance. Hofer, 981 F.2d at 380. Plaintiff has now, however, used an expert witness report to support this argument. The report purports to show that when a ’uzz‘e‘“ader s barre‘ bu‘ges, the bu‘ge is caused because of the same defect that causes barrels to ultimately explode. (See Doc. 67-7). A‘th“ugh this re”“rt was inc‘uded with ”‘aintiff s first motion to compel (Doc. 40-2), ”‘aintiff used the re”“rt ’ere‘y t“ sh“w that ”‘aintiff neverthe‘ess ”‘“wed f“rward trying t“ c“’”‘y with the C“urt[ ]s schedu‘ing “rder. (D“c. 40-1, at 6). At no point did plaintiff attempt to use the report substantively or even exhibit recognition that the report c“u‘d be used substantive‘y. In sh“rt, ”‘aintiff s sec“nd ’“ti“n t“ c“’”e‘ rehashes the arguments the Court previously decided, but now relies upon then-existing evidence for its substantive, rather than its procedural, value. The Court will therefore not entertain ”‘aintiff s argu’ent that the bu‘ged barre‘s sh“u‘d n“w be inc‘uded within the sc“”e “f discovery. It may be that plaintiff is correct that bulged barrels reflect firearms that will soon explode with repeated firings. Plaintiff, however, should have supported that 2 Metallurgy is the branch of science concerned with the physical and chemical behavior of metallic elements, their intermetallic compounds, and their mixtures. 8 argument with proper evidence in the first instance instead of resubmitting his motion with newfound considerations of the same evidence.3 Even if the Court were inclined to grant the motion, however, the Court is doubtful that defendants could produce additional materials. Defendants attested in their resistance that ”‘aintiff s ’“ti“n is with“ut ’erit as a‘‘ c“’”‘aints re‘ating t“ bu‘ged barre‘s have been provided as part of the production of the Palatka materials. There is no benefit to[ ] c“’”e‘‘ing ”r“ducti“n “f d“cu’ents that P‘aintiff a‘ready ”“ssesses. (D“c. 70, at 5). The Palatka ’ateria‘s referenced in defendants resistance are the discovery materials produced in Palatka v. Savage Arms, Inc., No. 1:10-cv-626, 2015 WL 13621441 (Mar. 31, 2015). Plaintiff in the instant case requested that defendants produce the entire body of discovery that was produced in Palatka. Defendants, seemingly, complied. Thus, plaintiff should be in possession of all discovery that was produced in Palatka. In acc“rdance with this C“urt s ”ri“r Order (D“c. 62), defendant has a‘ready provided a sworn declaration to plaintiff that defendant has produced all of the materials produced in any previous litigation. (See also Doc. 67-2, at ¶ 21). Defendants state’ent that a‘‘ c“’”‘aints re‘ating t“ bu‘ged barre‘s were inc‘uded in the Palatka materials was made by two attorneys who are officers of the Court and have a duty of candor to the Court. Further, the legal profession is just that—a profession. Members of the legal profession should be able to rely upon one another to conduct themselves as professionals, which includes the basic courtesy of honesty regarding whether certain materials have been produced. Although the Court is not so naïve as to think all attorneys are honest on every “ccasi“n, the C“urt has n“ reas“n t“ d“ubt the truth “f defense c“unse‘ s insistence that plaintiff has received the materials he now seeks to compel, yet again. See Jones v. 3 The Court will also briefly note that in the absence of plaintiff using the report for its substantive value, the Court was under no obligation to make the argument that the report supported ”‘aintiff s ”“siti“n sua sponte. It is not the job of the Court to make the ”arties argu’ents f“r them, and the Court will not assume the role of advocate. 9 Derwinski, 1 Vet. A””. 596, 606 (Ct. A””. Vet. C‘. 1991) (finding that the C“urt ’ust be ab‘e t“ re‘y u”“n the re”resentati“ns “f th“se wh“ ”ractice bef“re it ). Indeed, the Court has not been advised of any previous misdeeds in this case. Thus, even if the Court were to compel defendants to produce all materials relating to bulged barrels, every indication shows that plaintiff would not receive any new material that he does not already possess. Should plaintiff later discover that defendants did withhold such information, plaintiff may petition the Court for appropriate sanctions. Further, the Court has explicitly considered the issue of whether defendants should be compelled to provide plaintiff with the contact information of other customers who returned their ’uzz‘e‘“aders due t“ bu‘ged barre‘s. The C“urt s ana‘ysis “f that issue surrounded the excessive number of interrogatories plaintiff propounded as opposed to the substantive request at issue. Defendants initially objected to certain “f ”‘aintiff s interrogatories as being in excess of the twenty-five interrogatories permitted without leave of court. FED. R. CIV. P. 33(a)(1). The C“urt u”he‘d defendants “bjecti“ns “n this basis and stated, in no uncertain terms: The Court notes that defendants have provided substantive responses to some of the interrogatories they contend are in excess of the number permitted. However, the Court will not compel defendants to provide any further responses to Interrogatories Seven through Twenty-Seven, as these are in excess of the twenty-five permitted interrogatories. (Doc. 62, at 15). The interrogatory requesting the contact information at issue is Interrogatory Number Eleven. Interrogatory Number Eleven, of course, falls within the range of Interrogatories Seven through Twenty-Seven, which the Court explicitly found were in excess “f the nu’ber ”er’itted. This issue, just as the definiti“n “f “ther si’i‘ar instances has a‘ready been ‘itigated. The C“urt wi‘‘ n“t revisit this issue absent a compelling reason. As such, ”‘aintiff s ’“ti“n with respect to bulged barrels and customer contact information is denied. 10 Further, defendants provided the Court with a spreadsheet purporting to identify the exact Bates-Numbered pages at which plaintiff may find the contact information for other customers who returned their muzzleloaders due to bulged barrels. (Doc. 70-1). On its face, the spreadsheet is clear and identifies only a few pages to which plaintiff would have to turn for each customer to locate the information requested. Plaintiff is thus capable of readily identifying the contact information for each customer at issue. The Court is unclear what plaintiff means by compelling defendants to produce the requested information in as c“nvenient form as possible. (Doc. 67, at 2). Plaintiff does not specify whether he requests the information be produced in the most convenient form for defendants to assemble it or whether he requests that it be produced in the most convenient form possible for plaintiff to analyze it. Either way, plaintiff has mistaken the standard for the production of such information. Federal Rule of Civil Procedure 33(d) a‘‘“ws a ”arty t“ ”r“duce business rec“rds in res”“nse t“ an interr“gat“ry if the burden of deriving “r ascertaining the answer wi‘‘ be substantia‘‘y the sa’e f“r either ”arty. Plaintiff has not alleged that defendants are in possession of the requested information in any form other than within the business records identified in the aforementioned spreadsheet. Plaintiff, likewise, does not contend that he faces a greater burden in ascertaining the information than defendants would face in culling through the records indicated “n the s”readsheet t“ ‘“cate the inf“r’ati“n. As such, ”‘aintiff s request is without merit. B. Muzzleloader Return Team Defendants resistance ”r“vides that [”]‘aintiff is in ”“ssessi“n “f a‘‘ inf“r’ati“n known to exist (save for privileged communications with counsel) regarding [the ’uzz‘e‘“ader return tea’]. (D“c. 70, at 6-7). P‘aintiff s ”“siti“n is that ”‘aintiff requested inf“r’ati“n surr“unding the ’uzz‘e‘“ader return tea’ in severa‘ different 11 interr“gat“ries and requests f“r ”r“ducti“n. (D“c. 71, at 5). In Dece’ber 2017, the Court ordered defendants to provide plaintiff with a sworn declaration that they had di‘igent‘y and in g““d faith searched f“r res”“nsive d“cu’ents and [had] ”r“duced a‘‘ res”“nsive d“cu’ents they ‘“cated. (D“c. 62, at 16). If the information regarding the muzzleloader return team was truly requested by plaintiff in its requests for production and interr“gat“ries ”r“”“unded ”ri“r t“ the C“urt s first Order, such inf“r’ati“n w“u‘d have fallen within the purview of the previously required declaration. Although plaintiff should understand his own discovery requests better than anyone, the Court will not make such an assumption in the instant case. The Court has no reason to doubt that defendants have produced all discovery requested with respect to the muzzleloader return team. To prevent relitigation of this issue, however, the Court will require defendants to supplement their discovery responses with a sworn statement that they have conducted a diligent and good faith search for all requested discovery materials with respect to the muzzleloader return team and that all materials that have been located have, in fact, been produced. Of course, if defendants cannot make this statement truthfully, they should supplement their discovery responses accordingly prior to issuing the statement. This statement should be unnecessarily redundant because, as shown supra, this statement should have been implicitly included in defendants prior sworn statement. The Court will not require defendants to produce a similar statement with respect to each discovery request, especially given the blanket declaration defendants have already made. C. Sanctions The C“urt wi‘‘ turn n“w t“ defendants ’“ti“n f“r sancti“ns. A‘th“ugh the C“urt will not grant sanctions in response to the current motion, the Court will strongly consider granting sanctions should plaintiff bring future unwarranted motions. See Willhite v. 12 Collins, 459 F.3d 866 (8th Cir. 2006) (finding that monetary sanctions, a requirement that counsel take and pass a law school course, and temporary suspensi“n “f c“unse‘ s ‘aw license were all appropriate sanctions for counsel having improperly brought a case before the court). Although the parties are welcome to bring genuine issues before the Court, plaintiff is cautioned against bringing issues before the Court that have already been litigated. Defendants ’“ti“n f“r sancti“ns is denied. IV. CONCLUSION F“r the reas“ns set f“rth ab“ve, P‘aintiff s M“ti“n t“ C“’”e‘ Disc“very and Request for Expedited Relief is denied. (D“c. 67). Defendants ’“ti“n f“r sanctions is denied. (Doc. 70, at 7-8). Defendants are directed to provide a declaration that they have conducted a diligent and good faith search for all requested discovery materials with respect to the muzzleloader return team and that all materials that have been located have, in fact, been produced. IT IS SO ORDERED this 22nd day of March, 2018. __________________________________ C.J. Williams Chief United States Magistrate Judge Northern District of Iowa 13
]]>
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You
should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google
Privacy Policy and
Terms of Service apply.
