Jena Reyes and Ricardo Reyes v. Adam Smith, M.D., Adam Smith, M.D., P.C., Tri-State Specialists, L.L.P., Pierce Street Same Day Surgery, L.C., UnityPoint Health and Northwest Iowa Hospital Corporation, d/b/a St. Luke's Regional Medical Center of Sioux City, 21-0303

Jena and Ricardo Reyes sued Dr. Adam Smith and health-care entities alleging medical malpractice; amended petition filed Feb 2020 and defendant answered Feb 6, 2020.
On Feb 24, 2020 Reyes filed a certificate of merit from Dr. Richard Marfuggi asserting breach of care.
A joint scheduling plan set an expert-designation deadline (listed as July 7, 2020; plaintiffs dispute and assert an August 4 date); plaintiffs did not designate by that deadline.
Defendants designated experts on Oct 5, 2020 and moved for summary judgment on Oct 6 based on plaintiffs’ failure to designate; plaintiffs disclosed Dr. Marfuggi Oct 9 and moved Oct 22 for additional time, citing substantial compliance and COVID-19-related calendaring error.
The district court denied the extension request and granted summary judgment for defendants for lack of admissible expert testimony; the court of appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Motion for enlargement of time to designate expert under Iowa Code §668.11	Substantial compliance via prior certificate of merit naming Dr. Marfuggi; COVID-19 caused calendaring error, so good cause exists	Certificate of merit does not substitute for §668.11 disclosure; 66‑day delay was substantial and prejudiced defendants’ strategic advantage	Denial affirmed: certificate of merit and general COVID claim do not show substantial compliance or good cause; delay and lack of evidentiary support showed want of ordinary care
Summary judgment on malpractice claim	Denial of extension made summary judgment improper because plaintiffs would be left without their expert	Without an admissible expert, plaintiffs cannot meet the required proof in a medical‑malpractice claim	Grant of summary judgment affirmed: plaintiffs lacked expert testimony required to survive summary judgment

Hill v. McCartney, 590 N.W.2d 52 (Iowa Ct. App. 1998) (abuse‑of‑discretion standard for extending expert‑designation time)
Kunde v. Estate of Bowman, 920 N.W.2d 803 (Iowa 2018) (summary judgment review and view of record in favor of nonmoving party)
Hantsbarger v. Coffin, 501 N.W.2d 501 (Iowa 1993) (legislative intent of expert‑disclosure rule to prevent last‑minute surprises)
Superior/Ideal, Inc. v. Bd. of Review, 419 N.W.2d 405 (Iowa 1988) (substantial compliance doctrine explained)
Nedved v. Welch, 585 N.W.2d 238 (Iowa 1998) (definition and standards for "good cause" to excuse procedural defaults)
Donovan v. State, 445 N.W.2d 763 (Iowa 1989) (defaults not vacated for mere neglect; movant must show excusable neglect)
McHugh v. Smith, 966 N.W.2d 285 (Iowa Ct. App. 2021) (certificate of merit and §668.11 serve distinct purposes)
Kennis v. Mercy Hosp. Med. Ctr., 491 N.W.2d 161 (Iowa 1992) (expert testimony required to prove medical malpractice)