The Iowa Supreme Court issued an interesting opinion Estate of Butterfield v. Chautauqua Guest Home, Inc. addresses Iowa’s five-year-old certificate of merit requirement in medical malpractice lawsuits.
Background Facts and Proceedings
This is a medical malpractice bed sore case alleging wrongful death. The case revolves around injuries Ms. Butterfield allegedly suffered while caring for Chautauqua Guest Home, Inc., a skilled nursing facility. About a year before her ultimate death, her leg was injured while she was being moved from the bathroom to a wheelchair by the Chautauqua caretakers. She was taken to the hospital six days later, where she was diagnosed with a left hip fracture, which required surgery.
Butterfield returned to Chautauqua a few days later. At that point, she had no pressure injuries or skin problems. Over the next few months, she spent a lot of time in bed. She developed a blister on her left buttock, which grew significantly and eventually became infected, emitting a foul odor as bed sores do. The bed sores eventually caused her death.
A year later, Butterfield’s estate filed the medical malpractice lawsuit currently in question. Discovery ensued. After the statute of limitations passed, Chautauqua moved to dismiss the case with prejudice according to Iowa Code section 147.140. Following a hearing, the trial court dismissed the bed sore lawsuits. Iowa’s intermediate court affirmed and the case went to the state’s Supreme Court.