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

CourtSupreme Court of Iowa
DecidedMarch 20, 2026
Docket23-2113
StatusPublished

This text of Jenna Sondag v. Orthopaedic Speciatists, P.C. and John Hoffman, M.D. (Jenna Sondag v. Orthopaedic Speciatists, P.C. and John Hoffman, M.D.) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jenna Sondag v. Orthopaedic Speciatists, P.C. and John Hoffman, M.D., (iowa 2026).

Opinion

In the Iowa Supreme Court

No. 23–2113

Submitted October 7, 2025—Filed March 20, 2026

Jenna Sondag,

Appellant,

vs.

Orthopaedic Specialists, P.C., and John Hoffman,

Appellees.

On review from the Iowa Court of Appeals.

Appeal from the Iowa District Court for Scott County, Stuart P.

Werling, judge.

A plaintiff appeals the dismissal of her medical malpractice suit due to her

failure to timely designate an expert witness. Decision of Court of Appeals

Vacated, District Court Judgment Reversed and Case Remanded.

Christensen, C.J., delivered the opinion of the court, in which all

participating justices joined. McDonald, J., filed a concurring opinion.

Waterman, J., took no part in the consideration or decision of the case.

Roxanne Conlin and Devin Kelly of Roxanne Conlin & Associates, P.C.,

Des Moines, for appellant.

Ian J. Russell and Alexander C. Barnett of Lane & Waterman LLP,

Davenport, for appellees. 2

Christensen, Chief Justice.

This appeal arises from a medical malpractice action filed by Sondag1 on

January 7, 2019. Approximately eight months later, the defendants filed a

motion for summary judgment alleging Sondag failed to timely designate an

expert. One month later, Sondag filed a motion for extension of time within which

to name expert witnesses. The district court held a hearing on the parties’

motions, and an order was entered finding good cause existed to sustain

Sondag’s motion for extension of time and denying the defendants’ motion for

summary judgment. Hoffman did not apply for interlocutory appeal.

Nearly four years later, and only four days before trial, the district court

held a hearing before the same judge on the parties’ motions in limine. When the

court asked the defendants whether paragraph seventeen of their motion in

limine was essentially a renewal of their 2019 motion for summary judgment,

the defendants agreed. The court overturned its 2019 finding of good cause to

extend Sondag’s deadline and dismissed the action for failure to timely certify an

expert witness. Sondag appealed, and the court of appeals upheld the district

court’s dismissal. After further review, we vacate the decision of the court of

appeals, reverse the judgment of the district court, and remand the case for trial.

I. Background Facts and Proceedings.

Dr. John Hoffman of Orthopaedic Specialists, P.C., performed Jenna

Sondag’s hip surgery on February 13, 2017. After filing suit on January 7, 2019,

Sondag stipulated to a discovery plan that required her to designate expert

witnesses by the “deadline set forth in [section] 668.11.” This set Sondag’s expert

witness designation deadline for July 24, 2019. Sondag’s counsel later argued

1Plaintiffs Jenna Sondag, Timothy Sondag, and minors C.S. and B.S. are referred to

collectively as “Sondag” for simplicity. 3

that she failed to properly calendar the date because the law firm’s docketing

software “incorrectly calendared the expert deadlines in this case to the typical

deadlines of other civil-tort based claims.”

During April through July of 2019, Sondag’s counsel was preparing for

and participating in a six-week-long trial in a different case. See Godfrey v. State,

847 N.W.2d 578 (Iowa 2014); Godfrey v. State, 962 N.W.2d 84 (Iowa 2021). That

trial was further complicated by medical concerns that required the

hospitalization of one of Sondag’s attorneys. After being hospitalized for a day

and taking a week to recover, the attorney returned to court to finish out the

remainder of the trial, which was completed on July 15.

On October 7, the defendants filed a motion for summary judgment due to

Sondag’s failure to timely serve her expert certifications and disclosures. Sondag

resisted the summary judgment motion and moved for an extension of time to

certify and disclose expert witnesses. After hearing argument on the competing

motions, the court granted Sondag’s request for additional time and extended

the deadline. The court determined that the good cause requirement in Iowa

Code section 668.11(2) (2019) had been satisfied due to the explanations

outlined by Sondag’s attorney (busy trial schedule, medical complications, and

docketing software errors).

On October 26, 2023, four days before trial was to commence and nearly

four years after the court denied the defendants’ motion for summary judgment,

the court reconsidered its 2019 order when the defendants filed a motion in

limine to decertify Sondag’s expert witness. After considering unpublished

caselaw from the court of appeals and hearing argument by counsel, the court

reversed its prior ruling and decertified Sondag’s expert, indicating that it was

“required” to grant the motion. Unlike the 2019 detailed seven-page order finding 4

good cause, the 2023 order was short and sweet, referring to “the reasons set

forth on the record” as justifying the dismissal.

Sondag appealed, and we transferred the case to the court of appeals. The

court of appeals affirmed, and we granted Sondag’s application for further

review.

II. Analysis.

Upon further review, we hold that (1) the district court had authority to

correct an erroneous ruling any time prior to final judgment, (2) the district

court’s 2019 order was not an abuse of discretion, and (3) the district court’s

2023 ruling was an abuse of discretion. Accordingly, we vacate the decision of

the court of appeals, reverse the judgment of the district court, and remand the

case for trial.

A. The District Court Had Authority to Correct an Erroneous Ruling

Prior to Final Judgment. While Sondag may be correct that the motion to

disqualify her expert witness amounted to an untimely motion for summary

judgment, the district court generally has the authority to correct an erroneous

ruling at any time prior to final judgment. Kendall/Hunt Publ’g Co. v. Rowe, 424

N.W.2d 235, 240 (Iowa 1988). A judge is not typically bound by a prior ruling

that the judge later comes to believe is erroneous, and to say otherwise would

result in absurd outcomes. We see no reason this rule should not hold true for

Sondag. The correction of an erroneous ruling prior to final judgment is in the

interests of our judicial system, and how an erroneous ruling is called to the

attention of the court is ultimately immaterial.

B. The District Court’s 2019 Order. With respect to the district court’s

2019 order, we conclude the district court did not abuse its discretion in finding

good cause existed to sustain Sondag’s motion for extension of time to disclose

an expert witness and denying the defendants’ motion for summary judgment. 5

Iowa Code section 668.11(2) requires that “[i]f a party fails to disclose an expert

pursuant to subsection 1 or does not make the expert available for discovery,

the expert shall be prohibited from testifying in the action unless leave for the

expert’s testimony is given by the court for good cause shown.” Here, the critical

issue is whether the district court abused its discretion when it ruled that

Sondag had good cause for her failure to timely disclose an expert in 2019.

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