Cornelius Davis v. Iowa District Court for Scott County, 943 N.W.2d 58

Dr. Cornelius Davis (plaintiff) sued Genesis Health Systems and Davenport Surgical Group (DSG) and individual doctors after losing clinical privileges; the district court set a mandatory pretrial settlement conference and ordered “All parties with authority to settle must be present.”
Seventh Judicial District local rule 7.1 likewise requires personal attendance by all parties unless excused by the settlement judge.
A summary-judgment motion was pending; DSG’s request to be excused was denied. Davis’s counsel told the court Davis was in surgery but available by phone and did not inform the court Davis would not appear in person or seek clarification.
DSG and Genesis attended the conference with representatives; Davis did not. DSG sought $4,000 in sanctions (including $1,500 lost income for Dr. Lohmuller and $2,500 attorney fees/mileage); Genesis sought $500.
The district court found Davis violated its pretrial orders, granted DSG’s motion (ordering Davis and/or counsel to pay $1,500 to Dr. Lohmuller and $2,500 to DSG’s attorney), denied Genesis’s request, and denied Davis’s motion to rescind; Davis petitioned the Iowa Supreme Court for certiorari and obtained a stay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Authority to require parties’ personal attendance at settlement conferences	Davis: rule 1.602(1) does not explicitly require represented parties to appear; local rule 7.1 improperly enacted	Defs: district court has inherent authority and local rule supports mandatory attendance	Court: district courts have inherent authority and may require personal attendance; rule 1.602 permits such practice
Validity/enforceability of local rule 7.1 and trial-setting orders	Davis: local rule was not properly enacted and trial-setting language was vague/boilerplate	Defs: pretrial orders and rule 7.1 plainly required party presence; boilerplate does not negate enforceability	Court: trial-setting orders and rule 7.1 reasonably put Davis on notice; boilerplate does not excuse noncompliance
Authority to impose monetary sanctions (costs/fees) for nonattendance	Davis: sanction inconsistent with Iowa Rules and sanction guidelines; absence was mistake	Defs: rule 1.602(5) authorizes sanctions including payment of reasonable expenses unless justified	Court: rule 1.602(5) provides authority to award reasonable expenses; district court acted within law
Whether sanction was an abuse of discretion / amount reasonable	Davis: ordering expenses was arbitrary and excessive; process uneven	Defs: DSG incurred lost income and fees; amount was reasonable	Court: no abuse of discretion; amounts not challenged on record and therefore waived; sanction upheld

Barnhill v. Iowa Dist. Ct., 765 N.W.2d 267 (Iowa 2009) (writ of certiorari is proper vehicle to review sanction orders)
State Pub. Def. v. Iowa Dist. Ct., 747 N.W.2d 218 (Iowa 2008) (writ lies where lower court exceeded jurisdiction or acted illegally)
Crowell v. State Pub. Def., 845 N.W.2d 676 (Iowa 2014) (appellate review is for errors at law)
Ostergren v. Iowa Dist. Ct., 863 N.W.2d 294 (Iowa 2015) (district courts may adopt docket-management rules; certiorari relief limited to sustain or annul)
Fry v. Blauvelt, 818 N.W.2d 123 (Iowa 2012) (district courts may order and enforce attendance at pretrial conferences)
Hearity v. Iowa Dist. Ct., 440 N.W.2d 860 (Iowa 1989) (recognizes inherent power to manage dockets but notes fees require statutory or rule-based authority)
G. Heileman Brewing Co. v. Joseph Oat Corp., 871 F.2d 648 (7th Cir. 1989) (Rule 16 interpreted to allow courts to require party participation as an exercise of inherent authority)
Universal Coops., Inc. v. Tribal Co-op. Mktg. Dev. Fed'n of India, Ltd., 45 F.3d 1194 (8th Cir. 1995) (sanctions affirmed where party failed to present authorized representative at settlement conference)
Langenbau v. Med-trans Corp., 167 F. Supp. 3d 983 (N.D. Iowa 2016) (scheduling-order boilerplate is enforceable and not an excuse for noncompliance)