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McNeal v. Northwest Iowa Hospital Corp.
Citations: 812 N.W.2d 722; 2012 Iowa App. LEXIS 251; 2012 WL 1066500Docket: No. 11-1036
Court: Court of Appeals of Iowa; March 28, 2012; Iowa; State Appellate Court
The McNeals appealed a district court order granting summary judgment to St. Luke's Hospital regarding their claim for negligent infliction of emotional distress. Crystal McNeal, a pediatric patient, had her teddy bear repositioned by a nurse during her surgery, which the McNeals perceived as evoking images of a lynching due to their racial background. They refused to allow the nurse to move the bear and later sued the hospital, claiming emotional distress. The district court held that the McNeals failed to demonstrate circumstances warranting an exception to the rule that emotional distress claims typically require a physical injury. The court reiterated that the existence of a duty in such cases is a legal question for the court, suitable for summary judgment. The McNeals contended that the court misinterpreted Iowa law regarding emotional distress claims without physical injury. However, the appellate review affirmed the district court's ruling, concluding that the nurse's actions did not fall into the limited exceptions recognized by Iowa law for such claims, as supported by previous case law. Medical services in question do not involve life-and-death circumstances that would lead to mental anguish due to breach of contract. The court referenced established precedents indicating that claims for negligent infliction of emotional distress can arise from contractual relationships involving deeply emotional services, but found that Crystal's ear surgery does not meet this threshold. Additionally, there was no evidence that Crystal's uncle, Lee McNeal, had a contractual relationship with the hospital. As a result, the district court's summary judgment in favor of St. Luke’s was affirmed. The McNeals previously raised claims of intentional infliction of emotional distress and civil rights violations but later dismissed them. Initially, Judge Sokolovske denied St. Luke’s motion for summary judgment, but Judge Jacobson later reversed this ruling after re-evaluating the case. Iowa law permits a district court to reconsider prior interlocutory rulings, which the court noted was applicable here. The court clarified that it was incorrect for the McNeals to interpret the ruling as a denial of a cause of action for negligent infliction of emotional distress, as Iowa law generally requires a physical injury for such claims, with limited exceptions. Thus, the court did not address whether Crystal's emotional distress was due to Ray McNeal's actions regarding a teddy bear prior to her return to the room.