Estate of Butterfield v. Chautauqua Guest Home, Inc.
Annotate this Case
The Supreme Court reversed in part the judgment of the court of appeals affirming the district court's dismissal of the medical malpractice action brought by the Estate of Roberta Butterfield against Chautauqua Guest Home, Inc., a nursing home, holding that the Estate was not required to serve a certificate of merit affidavit on Chautauqua in this case.
While the Estate brought its action it did not serve a certificate of merit on Chautauqua. Chautauqua filed a motion to dismiss the claims against it with prejudice under Iowa Code 147.140. The district court granted the motion, and the court of appeals affirmed the dismissal of the Estate's claims. The Supreme Court reversed in part, holding (1) the certificate of merit requirement set forth in section 147.140 does not apply to plaintiffs who need experts solely for causation, as opposed to the standard of care or breach; and (2) remand was required to establish which of the Estate's claims survived the failure to file the certificate of merit.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.