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Court: Iowa Supreme Court
Docket:
22-1317
Opinion Date: November 8, 2024
Judge:
May
Areas of Law:
Civil Procedure, Medical Malpractice, Personal Injury
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A baby, S.K., was injured during labor and delivery, allegedly due to the negligence of the delivering doctor, Dr. Goodman, who used a Mityvac obstetrical vacuum delivery system. The plaintiff, S.K.'s conservator, claimed that the use of the vacuum caused brain damage to S.K. and sought damages from Dr. Goodman’s employer, Obstetric & Gynecologic Associates of Iowa City and Coralville, P.C. (the clinic).
A jury in the Iowa District Court for Johnson County found in favor of the plaintiff, awarding substantial damages. The clinic appealed, arguing that the district court erred in admitting a package insert from the vacuum, which contained hearsay statements about when the vacuum should not be used and potential harms from its use. The clinic contended that the insert's admission violated Iowa’s hearsay rule and prejudiced the trial's outcome.
The Iowa Supreme Court reviewed the case and agreed with the clinic. The court found that the package insert contained hearsay and did not fit within any recognized exceptions, including the residual exception and the market reports exception. The court noted that the insert's admission was prejudicial, as it directly addressed a central dispute in the case and was emphasized in the plaintiff's closing argument. The court concluded that the erroneous admission of the insert deprived the clinic of a fair trial.
The Iowa Supreme Court reversed the district court's judgment and remanded the case for a new trial. The court also addressed a procedural issue raised by the clinic regarding the plaintiff's certificate of merit affidavit, ultimately denying the clinic's motion to reverse on those grounds.
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