Mengwasser v. Comito
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The Supreme Court remanded this case for a new trial, holding that the district court misapplied changes to the Iowa Rules of Civil Procedure when it excluded certain evidence in this case, and the ruling may have affected the outcome of trial.
In 2014, the amendments to the Iowa Rules of Civil Procedure were adopted, inspired by prior changes to the federal rules. In the instant case, the district court excluded certain expert opinions of Plaintiff's treating chiropractor on the grounds that the chiropractor had not formed those opinions during treatment and Plaintiff had not submitted a timely expert report required under Iowa R. Civ. P. 1.500(2)(b). The Supreme Court reversed, holding that because the 2014 rule changes allow parties to submit more limited rule 1.500(2)(c) disclosures for experts who have not been retained for purposes of litigation the district court abused its discretion in its evidentiary ruling.
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