## Facts

- In March 1999, Georgia Rathje, a teenager, entered an alcohol-abuse treatment program at Mercy Hospital under the care of Dr. Dwight Schroeder.
- Schroeder prescribed Antabuse (disulfiram), a medication associated with serious adverse reactions.
- Within days, Georgia developed worsening symptoms including nausea and later jaundice.
- On April 23, 1999, Georgia was evaluated by her family physician, Dr. Jerome Janda, for stomach complaints.
- By April 26, 1999, Georgia’s condition had significantly worsened; Janda observed jaundice and arranged hospital admission and diagnostic work-up.
- On April 27, 1999, testing and consultation resulted in a working diagnosis of possible hepatitis caused by Antabuse.
- Georgia ultimately suffered severe liver injury attributed to Antabuse and required a liver transplant.
- Georgia and her parents sued Mercy Hospital and Dr. Schroeder on April 26, 2001, alleging negligent prescribing, inadequate warnings, and failure to monitor and respond to toxicity.

## Issues

1. Under Iowa Code § 614.1(9), does the two-year statute of limitations for medical malpractice begin to run upon discovery of the injury alone, or upon discovery of both the injury and its factual cause?
2. On this record, was summary judgment proper on the ground that the claim accrued more than two years before suit was filed?

## Decision

- The Iowa Supreme Court reversed summary judgment for Mercy Hospital and Dr. Schroeder and remanded.
- The court held that the limitations period begins when the plaintiff has actual or imputed knowledge of both the injury and its factual cause.
- The court concluded that when Georgia and her parents knew or should have known the causal connection between her liver injury and Antabuse/treatment was at least a fact question, making summary judgment inappropriate.

## Legal Principles

- For medical malpractice actions under Iowa Code § 614.1(9), accrual occurs upon discovery (actual or imputed) of both (1) the injury and (2) its factual cause.
- The discovery inquiry focuses on when a reasonable person would have sufficient information to prompt further investigation into the cause of the injury, not merely when symptoms or physical manifestations first exist.
- Prior statements that accrual begins upon “discovery of the injury” do not establish an injury-only rule when, in the earlier case, causation was known when the injury was discovered.
- If reasonable minds could differ on when the plaintiff should have discovered causation, the limitations question is not resolved as a matter of law on summary judgment.

## Conclusion

The court held that Iowa’s medical-malpractice limitations period starts when the plaintiff knew or should have known both the injury and its factual cause, and it remanded because the timing of that causal knowledge in this case could not be decided on summary judgment.


Rathje v. Mercy Hosp., 745 N.W.2d 443 (Iowa 2008)