patient rule (Iowa) · Go Syfert
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patient rule in Iowa

11 Iowa opinions name it 2 courts 1983–2026 2 in the last five years

The cases below were cited by Iowa courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Doe v. Johnstongreen
iowa · 1991 · cited in 2 Iowa opinions naming this issue, 2018–2026
2 sentences

2026By contrast, under the patient rule, the disclosure obligation is “shaped, not by what the medical community would deem material, but by the patient’s need for information.” Doe v. Johnston, 476 N.W.2d 28, 31 (Iowa 1991).

2018Under the patient rule, "the physician's duty to disclose is measured by the patient's need to have access to all information material to making a truly informed and intelligent decision concerning the proposed medical procedure." Pauscher , 408 N.W.2d at 359 (citing Cowman , 329 N.W.2d at 425 , 427 ); accord Doe , 476 N.W.2d at 31 ("That duty is shaped, not by what the medical community would deem material, but by the patient's need for information sufficient to make a truly informed and intelligent decision.").

22
Cowman v. Hornadaygreen
iowa · 1983 · cited in 2 Iowa opinions naming this issue, 1987–2018
2 sentences

2018Under the patient rule, "the physician's duty to disclose is measured by the patient's need to have access to all information material to making a truly informed and intelligent decision concerning the proposed medical procedure." Pauscher , 408 N.W.2d at 359 (citing Cowman , 329 N.W.2d at 425 , 427 ); accord Doe , 476 N.W.2d at 31 ("That duty is shaped, not by what the medical community would deem material, but by the patient's need for information sufficient to make a truly informed and intelligent decision.").

2018Under the patient rule, “the physician’s duty to disclose is measured by the patient’s need to have access to all information material to making a truly informed and intelligent decision concerning the proposed medical procedure.” Pauscher, 408 N.W.2d at 359 (citing Cowman, 329 N.W.2d at 425, 427 ); accord Doe, 476 N.W.2d at 31 (“That duty is shaped, not by what the medical community would deem material, but by the patient’s need for information sufficient to make a truly informed and intelligent decision.”).

22
Jerry W. Canterbury v. William Thornton Spence and the Washington Hospital Center, a Body Corporategreen
cadc · 1972 · cited in 2 Iowa opinions naming this issue, 1987–2018
2 sentences

2018See Doe , 476 N.W.2d at 31 (holding a physician must disclose reasonably available alternative methods of treatment even though such a requirement does not neatly fit within a strict construction of the patient rule language from Pauscher and Cowman ); Pauscher , 408 N.W.2d at 362 & n.2 (noting there is no bright-line that denotes when a risk is too remote to be material *539 and "[t]here is no bright line separating the significant from the insignificant; the answer in any case must abide a rule of reason" (quoting Canterbury v. Spence , 464 F.2d 772 , 788 (D.C.

2018See Doe, 476 N.W.2d at 31 (holding a physician must disclose reasonably available alternative methods of treatment even though such a requirement does not neatly fit within a strict construction of the patient rule language from Pauscher and Cowman); Pauscher, 408 N.W.2d at 362 & n.2 (noting there is no bright- line that denotes when a risk is too remote to be material and “[t]here is no bright line separating the significant from the insignificant; the answer in any case must abide a rule of reason” (quoting Canterbury v. Spence, 464 F.2d 772, 788 (D.C.

22
Pauscher v. Iowa Methodist Medical Centergreen
iowa · 1987 · cited in 4 Iowa opinions naming this issue, 1992–2026
2 sentences

2018And in Pauscher , we extended the patient rule's applicability to "all informed consent cases, in both elective and nonelective medical procedures." 408 N.W.2d at 359 . [T]he doctrine of informed consent arises out of the unquestioned principle that absent extenuating circumstances a patient has the right to exercise control over his or her body by making an informed decision concerning whether to submit to a particular medical procedure.

2018Under the patient rule, "the physician's duty to disclose is measured by the patient's need to have access to all information material to making a truly informed and intelligent decision concerning the proposed medical procedure." Pauscher , 408 N.W.2d at 359 (citing Cowman , 329 N.W.2d at 425 , 427 ); accord Doe , 476 N.W.2d at 31 ("That duty is shaped, not by what the medical community would deem material, but by the patient's need for information sufficient to make a truly informed and intelligent decision.").

14
Meier v. SENECAUT IIIgreen
iowa · 2002 · cited in 1 Iowa opinions naming this issue, 2025–2025
1 sentence

2025“It is a fundamental doctrine of appellate review that issues must ordinarily be both raised and decided by the district court before we will decide them on appeal.” Meier v. Senecaut, 641 N.W.2d 532, 537 (Iowa 2002).

11
Bradshaw v. Iowa Methodist Hospitalgreen
iowa · 1962 · cited in 1 Iowa opinions naming this issue, 1999–1999
2 sentences

1999Iowa Code § 622.10 (“The prohibition does not apply to cases where the person in whose favor the prohibition is made waives the right conferred .... ”); Bradshaw v. Iowa Methodist Hosp., 253 Iowa 1360, 1362 , 115 N.W.2d 816, 817 (1962) (holding that the section 622.10 privilege is personal to the patient and only the patient may claim or waive the confidentiality). *447 B.

1999Iowa Code § 622.10 (“The prohibition does not apply to cases where the person in whose favor the prohibition is made waives the right conferred .... ”); Bradshaw v. Iowa Methodist Hosp., 253 Iowa 1360, 1362 , 115 N.W.2d 816, 817 (1962) (holding that the section 622.10 privilege is personal to the patient and only the patient may claim or waive the confidentiality). *447 B.

11
Miller v. Kennedygreen
washctapp · 1974 · cited in 1 Iowa opinions naming this issue, 1987–1987
2 sentences

1987See Miller, 11 Wash.App. at 283 , 522 P.2d at 861 .

1987See Miller, 11 Wash.App. at 283 , 522 P.2d at 861 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Iowa. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Roosevelt Hotel Ltd. Partnership v. Sweeney green
iowa · 1986
2 sentences

2009Id. at 357 .

2009Id. at 357 .

22009–2009
State v. Stratton green
iowa · 1994
2 sentences

1999Stratton, 519 N.W.2d at 405 .

1999In State v. Stratton, 519 N.W.2d 403 (Iowa 1994), for example, we held that hospital medical records were not under the State’s control when they could not be seized by the prosecution or unilaterally procured without a patient waiver.

11999–1999
Van Iperen v. Van Bramer green
iowa · 1986
2 sentences

1987Today we confirm, as we implied in Van Iperen, 392 N.W.2d at 483 , that the patient rule is applicable in all informed consent cases, in both elective and nonelective medical procedures.

1987Cowman, 329 N.W.2d at 425, 427 ; see also Canterbury, 464 F.2d at 786-87 ; Van Iperen, 392 N.W.2d at 483 .

11987–1987
Sard v. Hardy green
md · 1977
2 sentences

1983A number of exceptions and qualifications are well capsulated in Sard, 281 Md. at 444-45 , 379 A.2d at 1022 -23: *426 [T]he physician retains a qualified privilege to withhold information on therapeutic grounds, as in those cases where a complete and candid disclosure of possible alternatives and consequences might have a detrimental effect on the physical or psychological well-being of the patient, or where the patient is incapable of giving his consent by reason of mental disability or infancy, or has specifically requested that he not be told.

1983A number of exceptions and qualifications are well capsulated in Sard, 281 Md. at 444-45 , 379 A.2d at 1022 -23: *426 [T]he physician retains a qualified privilege to withhold information on therapeutic grounds, as in those cases where a complete and candid disclosure of possible alternatives and consequences might have a detrimental effect on the physical or psychological well-being of the patient, or where the patient is incapable of giving his consent by reason of mental disability or infancy, or has specifically requested that he not be told.

11983–1983

Statutes the citing opinions construe

IA § Iowa Code § 622.10 (4) IA § Iowa Code § 147.137 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 12 (1977–2024) IA 11 (1983–2026) WI 11 (1977–2026) OR 10 (1984–2024) IN 8 (2003–2026) LA 8 (1972–2007) IL 8 (1991–2021) PA 8 (1904–2023) TX 8 (1954–2015) OH 8 (1901–2021) WA 7 (1988–2024) KY 7 (2009–2026) MO 7 (1914–2018) NY 6 (1984–2007) MA 5 (1985–2011) GA 5 (1993–2019) AR 4 (1992–2020) HI 4 (1978–2011) MS 3 (1980–2000) MI 3 (1904–2022) NJ 3 (1994–2015) NM 3 (1999–2026) NC 3 (1940–1982) ND 3 (1994–1997) FL 3 (2006–2026) VT 3 (1977–2006) AZ 3 (2009–2016) DE 3 (1989–2021) CO 2 (2013–2021) AL 2 (2005–2010) CT 2 (2013–2018) NH 2 (1989–2005) UT 2 (2013–2020) DC 2 (1997–2012) TN 2 (2020–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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