Jenna Sondag v. Orthopaedic Specialists, P.C. and John Hoffman, M.D.

Summary

The Iowa Supreme Court held that a district court may correct an erroneous ruling before final judgment but abused its discretion by revisiting a prior order extending the deadline for designating a medical-malpractice expert nearly four years later and excluding the expert shortly before trial. The court vacated the court of appeals decision, reversed the district court judgment dismissing the action, and remanded the case for trial.

Holdings

1. A district court generally has authority to correct an erroneous prior ruling at any time before final judgment, and the manner in which the alleged error is brought to the court's attention is immaterial.
2. The district court did not abuse its discretion in finding good cause under Iowa Code section 668.11(2) for Sondag's failure to timely designate an expert and in extending the deadline.
3. The district court abused its discretion by treating the original expert-designation deadline as controlling years after it had been extended, excluding the expert, and dismissing the action four days before trial.

Questions Presented

1. Whether the district court had authority to correct or reconsider an allegedly erroneous interlocutory ruling before final judgment.
2. Whether the district court abused its discretion in finding good cause under Iowa Code section 668.11(2) to extend Sondag's expert-designation deadline.
3. Whether the district court abused its discretion by revisiting the prior extension four years later, excluding Sondag's expert, and dismissing the medical malpractice action shortly before trial.

Disposition

reversed_and_remanded