Tamaiysha Turner v. CCRC of Cedar Rapids, LLC, d/b/a Terrace Glen Village, LLC, and United Wisconsin Insurance Company, 20-1210

Background

Turner obtained an administrative order for alternate medical care in her workers’ compensation case; the district court entered that order as a judgment in January 2020 under Iowa Code § 86.42.
About three weeks later Turner filed for contempt, alleging the employer, CCRC, refused to authorize a prescription required by the judgment.
The prescription was submitted Wednesday and rejected; resubmitted Friday and rejected again; Turner filed for contempt Friday; on the following Monday the claim representative authorized the prescription and it was filled that day.
At the contempt hearing defense counsel consistently appeared and defended; the district court found the denial was a mistake, promptly corrected, and not willful contempt, and denied Turner’s contempt application and post-trial motion.
A caption/name discrepancy arose: Turner named “CCRC of Cedar Rapids, LLC, d/b/a Terrace Glen Village,” while filings and the district court’s contempt order used “CCRC of Grimes, LLC, d/b/a Kennybrook Village”; the court and parties did not dispute that CCRC of Cedar Rapids was the operative employer on appeal.
Turner appealed arguing (1) wrong employer named, (2) due process violation, (3) incorrect contempt standard applied, and (4) improper exclusion of exhibits; the court affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred by naming the wrong employer in its contempt ruling	Turner: wrong-entity naming meant the proper employer did not appear, warranting default or reversal	CCRC: counsel defended the matter; name confusion did not prejudice Turner; no substitution sought	Court: no reversible error; defense appeared and defended; issue not preserved for review when raised post-trial
Whether entry of judgment for an employer Turner did not name violated due process	Turner: entering judgment for a different-named employer denied her due process	CCRC: no due process issue; defendant defended and participated	Court: claim waived/not preserved (not raised below) and Turner cited no supporting authority
Whether court applied the correct contempt standard	Turner: court focused only on intent and ignored other elements (e.g., acting contrary to a known duty or unconcern whether right)	CCRC: court applied the proper standard and rejected willfulness based on testimony and prompt correction	Court: applied correct standard (citing contempt precedents) and did not abuse discretion in declining to hold contempt
Whether the court abused discretion by excluding Turner’s proposed exhibits (prior denials)	Turner: exhibits showed a pattern/absence of mistake and were admissible under rule 5.404(b)	CCRC: exhibits were not relevant to willfulness for the specific prescription denial	Court: exclusion was not an abuse of discretion; exhibits were not sufficiently tied to the contempt issue (court also noted preservation and record problems but bypassed forfeiture given context)

Key Cases Cited

Amro v. Iowa Dist. Ct., 429 N.W.2d 135 (Iowa 1988) (defines willful-disobedience standard for contempt)
In re Marriage of Jacobo, 526 N.W.2d 859 (Iowa 1995) (contempt standard language cited)
Mitchell v. Cedar Rapids Cmty. Sch. Dist., 832 N.W.2d 689 (Iowa 2013) (preservation of error principles)
Meier v. Senecaut, 641 N.W.2d 532 (Iowa 2002) (issues must be raised and decided below to preserve appellate review)
State v. Putman, 848 N.W.2d 1 (Iowa 2014) (admissibility of prior bad acts requires relevance to disputed issue)
Brooks v. Holtz, 661 N.W.2d 526 (Iowa 2003) (offer of proof rule and exceptions when substance is apparent)
In re Marriage of Swan, 526 N.W.2d 320 (Iowa 1995) (appellate review of contempt decisions; trial court discretion)