Dennis Lloyd Smith, individually and as conservator for Molly Burgess Smith v. Catholic Health Initiatives-Iowa Corp. d/b/a MercyOne Des Moines Medical Center, Sariah Steed, R.N.

Summary

The Iowa Court of Appeals affirmed summary judgment for Catholic Health Initiatives-Iowa Corp., doing business as MercyOne Des Moines Medical Center, and nurse Sariah Steed on Dennis Smith’s defamation claim. The court held that Steed’s characterization of Smith as “yelling” in his wife’s medical records was a non-actionable opinion or supportable interpretation of the encounter rather than an actionable statement of fact.

Holdings

1. Steed's descriptions of Smith as yelling were nonactionable opinions rather than actionable statements of fact.
2. Defendants were entitled to judgment as a matter of law because the undisputed facts established that the challenged statements were not actionable.

Questions Presented

1. Whether Steed's descriptions of Smith as yelling in the medical records were actionable statements of fact or nonactionable opinions.
2. Whether defendants were entitled to summary judgment on Smith's defamation claim.

Disposition

affirmed