Sondag v. Orthopaedic Specialists, P.C. - Medical Malpractice Appeal

Iowa Supreme Court

Filed March 20th, 2026

Detected March 21st, 2026

Summary

The Iowa Supreme Court issued an opinion in Sondag v. Orthopaedic Specialists, P.C., concerning a medical malpractice case. The court reviewed the dismissal of the case due to a decertified expert witness, affirming the lower court's decision to revisit a prior ruling on good cause for extending the expert witness deadline.

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What changed

The Iowa Supreme Court has issued its opinion in Case No. 23-2113, Jenna Sondag v. Orthopaedic Specialists, P.C. and John Hoffman, M.D. This medical malpractice appeal concerns the district court's order to decertify an expert witness and dismiss the plaintiff's case four days before trial. The Supreme Court affirmed the Court of Appeals' decision, holding that a trial judge has the authority to correct a prior ruling at any time before final judgment. Therefore, the district court was permitted to revisit its earlier determination of good cause for extending the expert witness deadline under Iowa Code section 668.11, ultimately decertifying the witness for lack of good cause.

This ruling has implications for medical malpractice litigation in Iowa, particularly regarding the timing and certification of expert witnesses. The decision underscores that prior rulings on good cause are not final and can be revisited by the trial court, especially in light of new legal precedent. Litigants in similar situations must ensure their expert witness certifications meet the required standards, as trial courts retain discretion to decertify experts even after initial approvals, potentially leading to case dismissal. The published opinion provides guidance on the application of Iowa Code section 668.11 and the court's discretion in managing pre-trial proceedings.

What to do next

Review expert witness certification procedures in light of the court's ruling on revisiting prior good-cause determinations.

Source document (simplified)

Main Content

Case No. 23-2113

Jenna Sondag

v.
Orthopaedic Speciatists, P.C. and John Hoffman, M.D.

In this medical malpractice action, Jenna Sondag appealed from the district court’s order decertifying an expert witness and dismissing her case four days before trial. The court of appeals affirmed. On further review, Ms. Sondag argues the district court erred when it, at the request of a pre-trial motion filed by Dr. John Hoffman and Orthopaedic Specialists, P.C., reversed a nearly four-year-old finding that good cause existed to extend her deadline to name expert witnesses under Iowa Code section 668.11 and dismissed the case for lacking a timely-certified expert witness.

County: Scott Trial Court Case No.: LACE131149

Applicant

Jenna Sondag

Resister

Orthopaedic Speciatists, P.C. and John Hoffman, M.D.

Attorneys for the Applicant

Roxanne Barton Conlin
Devin C. Kelly

Attorneys for the Resister

Ian J. Russell
Alexander C. Barnett

Supreme Court

Oral Argument Schedule

Non-Oral

Oct 07, 2025 1:30 PM

Briefs

Appellant Brief (281.94 KB)

Appellee Brief (391.40 KB)

Appellant Reply Brief (334.88 KB)

Supreme Court Opinion

Opinion Number:

23-2113

Date Published:

Mar 20, 2026

PDF of the Opinion (147.14 KB)

Court of Appeals

Court of Appeals Opinion

Opinion Number:

23-2113

Date Published:

Jan 23, 2025

Summary

Appeal from the Iowa District Court for Scott County, Stewart P. Werling, Judge. AFFIRMED. Heard by Greer, P.J., and Buller and Langholz, JJ. Opinion by Buller, J. (8 pages)

A plaintiff appeals dismissal of a medical negligence action based on decertification of her expert witness as untimely. OPINION HOLDS: Because a trial judge may correct a prior ruling any time before final judgment, the district court was permitted to revisit its prior good‑cause determination under Iowa Code section 668.11 (2019) four years after the initial determination. Finding the district court did not abuse its discretion in later decertifying the expert witness for an absence of good cause under section 668.11 in light of new unpublished caselaw from our court, we affirm.

PDF of the Opinion (160.94 KB)