## Facts

- Pamela Plowman received prenatal care in 2010–2011 from Dr. Leah Steffensmeier at Fort Madison Community Hospital.
- At about 22 weeks’ gestation, an ultrasound was performed and interpreted by radiologists Dr. Pil Kang and Dr. John Paiva.
- The ultrasound report noted fetal head abnormalities, reflected head measurements below roughly the third-to-sixth percentile, and recommended follow-up testing.
- Pamela alleged Dr. Steffensmeier told her the fetus was developing normally, did not disclose the reported abnormalities, and did not arrange follow-up testing.
- In August 2011, Pamela gave birth to Z.P., later diagnosed with cerebral palsy, microcephaly, visual impairment, intellectual disabilities, and a seizure disorder, requiring extensive care.
- The parents alleged that proper disclosure and follow-up would have identified the abnormalities prenatally and that Pamela would have chosen to terminate the pregnancy.
- The parents sought damages including ordinary and extraordinary child-rearing costs, loss of income, and emotional distress.

## Issues

1. Whether Iowa law recognizes a wrongful-birth cause of action framed as medical negligence based on failure to inform parents of prenatal test results indicating severe fetal abnormalities that would have led to a lawful abortion.

## Decision

- The Iowa Supreme Court reversed the district court’s grant of summary judgment for defendants and remanded.
- The court held wrongful birth is cognizable under Iowa law as a form of medical negligence.
- The court concluded the claim fits established negligence and informed-consent principles and is not barred by statute or public policy.

## Legal Principles

- A wrongful-birth claim may proceed when medical professionals allegedly fail to properly interpret, diagnose, and communicate prenatal abnormalities, thereby depriving parents of an informed reproductive choice.
- The actionable injury is not the child’s disability itself, but the loss of the opportunity to make an informed decision (including the option of lawful abortion) and the resulting economic and emotional consequences.
- Iowa’s prior rejection of wrongful-pregnancy claims involving the birth of a healthy child does not foreclose wrongful-birth claims involving severe congenital impairments and extraordinary care costs.
- Difficulty measuring damages does not categorically bar the cause of action; extraordinary medical and caregiving expenses provide a concrete damages component.

## Conclusion

The Iowa Supreme Court recognized wrongful birth as a valid medical negligence claim, allowing parents to seek damages when negligent nondisclosure of prenatal abnormalities allegedly prevented an informed decision to terminate a pregnancy and resulted in the birth of a severely disabled child.


Plowman v. Fort Madison Cmty. Hosp., 896 N.W.2d 393 (Iowa 2017)