Jahn Patric Kirlin and Sara Louise Kirlin v. Dr. Barclay A. Monaster, M.D.; Dr. Christian William Jones, M.D.; and Physicians Clinic d/b/a Methodist Physicians Clinic-Council Bluffs, 24-0205

Plaintiffs, Jahn and Sara Kirlin, filed a medical malpractice claim against Drs. Monaster and Jones, and Methodist Physicians Clinic (MPC), after Jahn Kirlin suffered a stroke following alleged negligent care and failure to order an MRI.
The initial case was voluntarily dismissed by the Kirlins after a dispute regarding the certificate of merit, then refiled with corrected expert documentation.
The district court granted summary judgment for the defendants both times, first for issues with the certificate of merit and second for missing the expert disclosure deadline under Iowa Code section 668.11 after remand.
After a successful appeal reinstating their claim, a dispute arose as to whether the expert disclosure deadline had expired during the appeal or a new timeline applied.
The district court sided with the defendants, finding Kirlins missed the post-remand deadline and lacked good cause for the late expert disclosures; the Supreme Court reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the expert disclosure deadline under 668.11 applies after an appeal and remand	Section 668.11 deadline lapsed during appeal, so default TSDP deadline (210 days before trial) applies	Pre-remand timeline tolled; only 29 days left after remand; deadline missed	Court bypassed issue; noted both positions plausible
Whether plaintiffs had good cause for late expert certification	Confusion/uncertainty over deadline; no prejudice to defense; plaintiffs diligent	Clear deadline existed; delay prejudiced defendants; no excuse for not seeking clarification	Court found good cause existed and district court abused discretion
Whether the late disclosure prejudiced defendants	No actual prejudice; defendants received info well before trial	Presumed prejudice – late disclosure harmed defense preparation	No real prejudice shown to defense
Impact of defense counsel conduct on good cause determination	Defendants equivocal on deadline; did not notify plaintiffs of strict position	Plaintiffs should have sought clarification; defense not responsible	Conduct of defense did not support strict enforcement

Hantsbarger v. Coffin, 501 N.W.2d 501 (Iowa 1993) (establishes good cause exception factors under section 668.11 for expert disclosures)
Nedved v. Welch, 585 N.W.2d 238 (Iowa 1998) (late expert disclosure not excused when delay lacked good cause)
Donovan v. State, 445 N.W.2d 763 (Iowa 1989) (upholds denial of late expert certification for lack of diligence)
Hill v. McCartney, 590 N.W.2d 52 (Iowa Ct. App. 1998) (untimely expert disclosure not excused by lack of expert; diligence required)