Alexandria M. Anderson, Individually and as Administrator of the Estate of Carter Jay William Anderson, and Terry Anderson, Individually v. State of Iowa, 2 N.W.3d 807

A ten-year-old child, Carter Anderson, died following medical treatment at the University of Iowa Hospitals and Clinics (UIHC).
The child’s mother, Alexandria Anderson, filed administrative tort claims on behalf of Carter’s estate before being officially appointed as administrator.
Later, Alexandria was appointed as administrator and continued to pursue the claims.
Alexandria and Terry Anderson (the parents) also sought damages for loss of consortium in their individual capacities, but did not file separate individual tort claims with the State as required.
The district court dismissed all claims for failure to exhaust administrative remedies under the Iowa Tort Claims Act (ITCA) and refused to admit new evidence during reconsideration.
Plaintiffs appealed the district court’s dismissal and exclusion of new evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether individual claims for consortium were properly exhausted under ITCA	Estate claim sufficient; individuals shouldn’t need separate filings	Each claimant must file separately per ITCA and rules	Dismissal of individual claims affirmed; parents did not file separate claims
Whether estate’s claims were valid despite pre-appointment filing by administrator	Ratification upon later appointment renders claims valid	Claims invalid if filed before appointment as administrator	Dismissal of estate’s claims reversed; ratification cured defect
Whether district court correctly refused to permit new evidence (medical records) at reconsideration	Medical records relevant to show parent status, would influence decision	Improper to submit new evidence at reconsideration; not relevant to presentment	Affirmed; district court did not abuse discretion in refusing new evidence
Whether Voss required dismissal of pre-appointment claims by administrators	Voss distinguishable; here claim done as prospective administrator, later ratified	Voss bars all actions where not appointed when filing	Voss distinguished; claims ratified by appointment, so not barred

Wagner v. State, 952 N.W.2d 843 (Iowa 2020) (describes partial waiver of sovereign immunity under ITCA)
Swanger v. State, 445 N.W.2d 344 (Iowa 1989) (administrative exhaustion is jurisdictional under ITCA)
Schneider v. State, 789 N.W.2d 138 (Iowa 2010) (presentment of administrative claims discussed)
Segura v. State, 889 N.W.2d 215 (Iowa 2017) (addressed sufficiency of administrative claim information)
Roth v. Evangelical Lutheran Good Samaritan Soc’y, 886 N.W.2d 601 (Iowa 2016) (parents may recover consortium for death of minor)
Bloomquist v. Wapello County, 500 N.W.2d 1 (Iowa 1993) (necessity of separate consortium claims)
In re Est. of Voss, 553 N.W.2d 878 (Iowa 1996) (filing by proper capacity needed for ITCA exhaustion)