continuous treatment rule (Iowa) · Go Syfert
← Iowa issues

continuous treatment rule in Iowa

5 Iowa opinions name it 2 courts 1995–2018 0 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 (4)

CaseFollowedCited
McClendon v. Beckgreen
iowa · 1997 · cited in 2 Iowa opinions naming this issue, 2005–2018
2 sentences

2018Id. at 385 .

2005Although we have been urged to adopt the doctrine in two cases, see McClendon v. Beck, 569 N.W.2d 382, 385 (Iowa 1997) and Langner, 533 N.W.2d at 519 , we have yet to adopt it.

12
Ratcliff v. Graethergreen
iowa · 2005 · cited in 1 Iowa opinions naming this issue, 2018–2018
2 sentences

2018Cedar Rapids Lodge & Suites, L.L.C. v. JFS Dev., Inc., 789 F.3d 821, 826 (8th Cir. 2015) (“The Iowa court, however, has declined to apply the continuous treatment rule when the plaintiff had notice of negligence prior to the termination of treatment . . .”); see also Ratcliff v. Graether, 697 N.W.2d 119, 125 (Iowa 2005) (“the doctrine does not apply when the plaintiff, as here, is on inquiry notice . . .”). 12 The district court ruled that where, as here, the client learned of the mistake/negligence prior to the cessation of the attorney-client relationship; the client was on inquiry notice.3

2018Cedar Rapids Lodge & Suites, L.L.C. v. JFS Dev., Inc., 789 F.3d 821, 826 (8th Cir. 2015) (“The Iowa court, however, has declined to apply the continuous treatment rule when the plaintiff had notice of negligence prior to the termination of treatment . . .”); see also Ratcliff v. Graether, 697 N.W.2d 119, 125 (Iowa 2005) (“the doctrine does not apply when the plaintiff, as here, is on inquiry notice . . .”). 12 The district court ruled that where, as here, the client learned of the mistake/negligence prior to the cessation of the attorney-client relationship; the client was on inquiry notice.3

11
Cedar Rapids Lodge & Suites, LLC v. JFS Development, Inc.green
ca8 · 2015 · cited in 1 Iowa opinions naming this issue, 2018–2018
2 sentences

2018Cedar Rapids Lodge & Suites, L.L.C. v. JFS Dev., Inc., 789 F.3d 821, 826 (8th Cir. 2015) (“The Iowa court, however, has declined to apply the continuous treatment rule when the plaintiff had notice of negligence prior to the termination of treatment . . .”); see also Ratcliff v. Graether, 697 N.W.2d 119, 125 (Iowa 2005) (“the doctrine does not apply when the plaintiff, as here, is on inquiry notice . . .”). 12 The district court ruled that where, as here, the client learned of the mistake/negligence prior to the cessation of the attorney-client relationship; the client was on inquiry notice.3

2018Cedar Rapids Lodge & Suites, L.L.C. v. JFS Dev., Inc., 789 F.3d 821, 826 (8th Cir. 2015) (“The Iowa court, however, has declined to apply the continuous treatment rule when the plaintiff had notice of negligence prior to the termination of treatment . . .”); see also Ratcliff v. Graether, 697 N.W.2d 119, 125 (Iowa 2005) (“the doctrine does not apply when the plaintiff, as here, is on inquiry notice . . .”). 12 The district court ruled that where, as here, the client learned of the mistake/negligence prior to the cessation of the attorney-client relationship; the client was on inquiry notice.3

11
Geraldine Goellner v. Julius Butler, M.D., University of Minnesotagreen
ca8 · 1988 · cited in 1 Iowa opinions naming this issue, 1995–1995
1 sentence

1995See also Goellner v. Butler, 836 F.2d 426, 430 (8th Cir.1988) (applying Minnesota law, court similarly concluded that a patient’s claim for negligence, negligent disclosure, and negligent misrepresentation against the physician and hospital regarding insertion of a Copper-7 intrauterine device was barred under the single act exception to the continuous treatment doctrine).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Betty Jean Brown, a Minor, by Owen Walter Brown, Her Guardian Ad Litem, and Owen Walter Brown v. United Statesgreen
ca9 · 1965 · cited in 1 Iowa opinions naming this issue, 1995–1995
1 sentence

1995But see Brown v. United States, 353 F.2d 578, 580 (9th Cir.1965) (“We cannot accept the proposition that one who continues to receive treatment from succeeding government physicians is, regardless of the circumstances, excused from conducting diligent inquiry into the conduct of a doctor with whom the personal relationship has been terminated and who is not claimed to have acted in direct concert with the succeeding physicians.”).

11

Also cited on this issue (3)

CaseCitedYears
Langner v. Simpson green
iowa · 1995
2 sentences

2005Although we have been urged to adopt the doctrine in two cases, see McClendon v. Beck, 569 N.W.2d 382, 385 (Iowa 1997) and Langner, 533 N.W.2d at 519 , we have yet to adopt it.

1997Id. at 520 .

21997–2005
Chrischilles v. Griswold green
iowa · 1967
2 sentences

2018We adopted the discovery rule for negligence claims in Chrischilles , reasoning [i]f an injured party is wholly unaware of the nature of his [or her] injury and the cause of it, it is difficult to see how he [or she] may be charged with a lack of diligence or sleeping on his [or her] rights. 260 Iowa at 461 , 150 N.W.2d at 100 .

2018We adopted the discovery rule for negligence claims in Chrischilles , reasoning [i]f an injured party is wholly unaware of the nature of his [or her] injury and the cause of it, it is difficult to see how he [or she] may be charged with a lack of diligence or sleeping on his [or her] rights. 260 Iowa at 461 , 150 N.W.2d at 100 .

12018–2018
Stanbury v. Bacardi green
tenn · 1997
1 sentence

2018The continuous-representation rule, like the continuous-treatment rule, constitutes "a particularized application of the discovery rule." See id . (quoting Stanbury , 953 S.W.2d at 676 ).

12018–2018

Statutes the citing opinions construe

IA § Iowa Code § 614.1 (5)

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

NY 470 (1975–2026) CT 27 (1990–2019) SC 12 (1996–2023) WY 11 (1988–2025) GA 11 (2000–2024) AR 10 (1990–2024) ND 7 (1986–2006) LA 6 (2001–2012) WI 6 (1980–2022) SD 6 (1988–2020) VA 6 (1993–2011) MA 5 (2001–2016) TX 5 (1984–1996) IA 5 (1995–2018) IL 4 (1991–2021) WV 4 (1996–2024) NE 3 (2006–2022) KS 3 (1996–1998) DC 3 (1997–2022) FL 3 (1983–1989) CA 2 (1994–2014) ME 2 (2008–2008) NM 2 (2002–2025) WA 2 (2011–2011) KY 2 (2020–2023)

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.

← Caselaw search · G Cite Topics · Brief Check