care standard (Iowa) · Go Syfert
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care standard in Iowa

10 Iowa opinions name it 2 courts 2015–2026 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 (11)

CaseFollowedCited
O'Neil v. Windshire Copeland Associates, L.P.green
vaed · 2002 · cited in 3 Iowa opinions naming this issue, 2016–2016
2 sentences

2016See O’Neil v. Windshire Copeland Assocs., L.P., 197 F. Supp. 2d 507, 510 (E.D.

2016The requirement is sufficiently specific to prescribe a standard of care the violation of which constitutes negligence per se. - See O’Neil v. Windshire Copeland Assocs., L.P., 197 F.Supp.2d 507, 510 (E.D.Va.2002) (ruling that apartment owner was negligent per se for having balcony, guardrail lower than required by city building code); Heath v. La Mariana Apartments, 143 N.M. 657 , 180 P.3d 664, 669-70 (2008) (violation of guardrail spacing requirement in ordinance would be negligence per se but for grandfather provision excusing landlord from obligation to upgrade railings to current code); c

33
Oswald v. LeGrandgreen
iowa · 1990 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017See Alcala, 880 N.W.2d at 709 (collecting cases requiring evidence of an employer’s standard of care and 73 its breach to recover under a negligent-training theory); Oswald v. LeGrand, 453 N.W.2d 634, 635 (Iowa 1990) (noting that in a professional negligence action, “[o]rdinarily, evidence of the applicable standard of care—and its breach—must be furnished by an expert”); Brandt v. Richter, 159 N.W.2d 471, 474 (Iowa 1968) (allowing testimony of farm safety expert and discussing precedent rejecting argument such testimony improperly altered the standard of care).

2017See Alcala, 880 N.W.2d at 709 (collecting cases requiring evidence of an employer’s standard of care and 73 its breach to recover under a negligent-training theory); Oswald v. LeGrand, 453 N.W.2d 634, 635 (Iowa 1990) (noting that in a professional negligence action, “[o]rdinarily, evidence of the applicable standard of care—and its breach—must be furnished by an expert”); Brandt v. Richter, 159 N.W.2d 471, 474 (Iowa 1968) (allowing testimony of farm safety expert and discussing precedent rejecting argument such testimony improperly altered the standard of care).

22
Brandt v. Richtergreen
iowa · 1968 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017See Alcala, 880 N.W.2d at 709 (collecting cases requiring evidence of an employer’s standard of care and 73 its breach to recover under a negligent-training theory); Oswald v. LeGrand, 453 N.W.2d 634, 635 (Iowa 1990) (noting that in a professional negligence action, “[o]rdinarily, evidence of the applicable standard of care—and its breach—must be furnished by an expert”); Brandt v. Richter, 159 N.W.2d 471, 474 (Iowa 1968) (allowing testimony of farm safety expert and discussing precedent rejecting argument such testimony improperly altered the standard of care).

2017See Alcala, 880 N.W.2d at 709 (collecting cases requiring evidence of an employer’s standard of care and 73 its breach to recover under a negligent-training theory); Oswald v. LeGrand, 453 N.W.2d 634, 635 (Iowa 1990) (noting that in a professional negligence action, “[o]rdinarily, evidence of the applicable standard of care—and its breach—must be furnished by an expert”); Brandt v. Richter, 159 N.W.2d 471, 474 (Iowa 1968) (allowing testimony of farm safety expert and discussing precedent rejecting argument such testimony improperly altered the standard of care).

22
Brenda J. Alcala v. Marriott International, Inc. and Courtyard Management Corporation D/B/A Quad Cities Courtyard by Marriottgreen
iowa · 2016 · cited in 2 Iowa opinions naming this issue, 2017–2017
2 sentences

2017See Alcala, 880 N.W.2d at 709 (collecting cases requiring evidence of an employer’s standard of care and 73 its breach to recover under a negligent-training theory); Oswald v. LeGrand, 453 N.W.2d 634, 635 (Iowa 1990) (noting that in a professional negligence action, “[o]rdinarily, evidence of the applicable standard of care—and its breach—must be furnished by an expert”); Brandt v. Richter, 159 N.W.2d 471, 474 (Iowa 1968) (allowing testimony of farm safety expert and discussing precedent rejecting argument such testimony improperly altered the standard of care).

2017See Alcala, 880 N.W.2d at 709 (collecting cases requiring evidence of an employer’s standard of care and 73 its breach to recover under a negligent-training theory); Oswald v. LeGrand, 453 N.W.2d 634, 635 (Iowa 1990) (noting that in a professional negligence action, “[o]rdinarily, evidence of the applicable standard of care—and its breach—must be furnished by an expert”); Brandt v. Richter, 159 N.W.2d 471, 474 (Iowa 1968) (allowing testimony of farm safety expert and discussing precedent rejecting argument such testimony improperly altered the standard of care).

22
Tina Haskenhoff v. Homeland Energy Solutions, LLCgreen
iowa · 2017 · cited in 1 Iowa opinions naming this issue, 2026–2026
2 sentences

2026Haskenhoff v. Homeland Energy Sols., LLC, 897 N.W.2d 553, 600 (Iowa 2017).

2026In response, the school district points us to our supreme court’s opinion in Haskenhoff requiring expert evidence of standard of care. 897 N.W.2d at 600 (“Expert testimony on the standard of care or standard of practice is generally permitted in negligence actions.”).

11
Hill v. McCartneygreen
iowactapp · 1998 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019See Hill, 590 N.W.2d at 56 .

11
In Re CBgreen
iowa · 2000 · cited in 1 Iowa opinions naming this issue, 2019–2019
1 sentence

2019See Iowa Code § 232.102 (9) (requiring the DHS to “make every reasonable effort to return the child to the child’s home as quickly as possible consistent with the best interests of the child”); In re C.B., 611 N.W.2d 489, 493 (Iowa 2000) (noting that “the scope of the efforts by the DHS to reunify parent and child after removal impacts the burden of proving those elements of termination electronic record provided to us on appeal can be difficult to navigate, we found these record citations to be especially helpful in aiding our review. 5 which require reunification efforts”).

11
Struve v. Payvandigreen
iowactapp · 2007 · cited in 1 Iowa opinions naming this issue, 2016–2016
1 sentence

2016The requirement is sufficiently specific to prescribe a standard of care the violation of which constitutes negligence per se. - See O’Neil v. Windshire Copeland Assocs., L.P., 197 F.Supp.2d 507, 510 (E.D.Va.2002) (ruling that apartment owner was negligent per se for having balcony, guardrail lower than required by city building code); Heath v. La Mariana Apartments, 143 N.M. 657 , 180 P.3d 664, 669-70 (2008) (violation of guardrail spacing requirement in ordinance would be negligence per se but for grandfather provision excusing landlord from obligation to upgrade railings to current code); c

11
Brichacek v. Hiskeygreen
iowa · 1987 · cited in 1 Iowa opinions naming this issue, 2016–2016
1 sentence

2016The requirement is sufficiently specific to prescribe a standard of care the violation of which constitutes negligence per se. - See O’Neil v. Windshire Copeland Assocs., L.P., 197 F.Supp.2d 507, 510 (E.D.Va.2002) (ruling that apartment owner was negligent per se for having balcony, guardrail lower than required by city building code); Heath v. La Mariana Apartments, 143 N.M. 657 , 180 P.3d 664, 669-70 (2008) (violation of guardrail spacing requirement in ordinance would be negligence per se but for grandfather provision excusing landlord from obligation to upgrade railings to current code); c

11
Heath Ex Rel. Holdyn H. v. La Mariana Apartmentsgreen
nm · 2008 · cited in 1 Iowa opinions naming this issue, 2016–2016
2 sentences

2016The requirement is sufficiently specific to prescribe a standard of care the violation of which constitutes negligence per se. - See O’Neil v. Windshire Copeland Assocs., L.P., 197 F.Supp.2d 507, 510 (E.D.Va.2002) (ruling that apartment owner was negligent per se for having balcony, guardrail lower than required by city building code); Heath v. La Mariana Apartments, 143 N.M. 657 , 180 P.3d 664, 669-70 (2008) (violation of guardrail spacing requirement in ordinance would be negligence per se but for grandfather provision excusing landlord from obligation to upgrade railings to current code); c

2016The requirement is sufficiently specific to prescribe a standard of care the violation of which constitutes negligence per se. - See O’Neil v. Windshire Copeland Assocs., L.P., 197 F.Supp.2d 507, 510 (E.D.Va.2002) (ruling that apartment owner was negligent per se for having balcony, guardrail lower than required by city building code); Heath v. La Mariana Apartments, 143 N.M. 657 , 180 P.3d 664, 669-70 (2008) (violation of guardrail spacing requirement in ordinance would be negligence per se but for grandfather provision excusing landlord from obligation to upgrade railings to current code); c

11
Burton v. Des Moines Metropolitan Transit Authoritygreen
iowa · 1995 · cited in 1 Iowa opinions naming this issue, 2015–2015
1 sentence

2015The standard of care instruction was based on Burton v. Des Moines Metropolitan Transit Authority, 530 N.W.2d 696, 700 (Iowa 1995).

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 (1)

CaseCitedYears
Kathryn Winger and Timothy Potts v. Cm Holdings, L.L.C. green
iowa · 2016
1 sentence

2024But an ordinance “requir[ing] forty-two-inch high guardrails on second-floor or higher balconies . . . is sufficiently specific to prescribe a standard of care the violation of which constitutes negligence per se.” Winger, 881 N.W.2d at 448 .

12024–2024

Statutes the citing opinions construe

IA § Iowa Code § 321.489 (3) IA § Iowa Code § 364.1 (3) IA § Iowa Code § 562A.15 (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

IL 16 (1959–2022) CA 15 (1933–2022) WA 14 (1979–2025) MS 14 (1980–2015) TX 13 (1894–2013) MI 10 (1944–2023) IA 10 (2015–2026) KY 7 (1942–2026) DE 6 (1994–2023) MO 5 (1994–2014) ID 5 (1985–2025) IN 4 (1941–2008) GA 4 (1988–1998) OH 4 (1991–2007) MT 4 (2006–2016) LA 4 (1982–2012) MD 4 (1993–2019) VA 3 (2010–2017) KS 3 (2000–2026) NM 3 (1951–2024) CO 3 (2007–2016) TN 3 (2005–2025) NC 3 (1980–2014) NY 3 (1912–2018) OR 3 (2000–2018) CT 3 (1996–2019) PA 2 (2012–2017) AL 2 (1983–2009) FL 2 (2018–2026) MA 2 (2013–2018)

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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