Renee Hummel v. Adam B. Smith, Adam Smith, M.D., P.C., and Tri-State Specialists, L.L.P.

Summary

The court held that Iowa's medical-malpractice expert-qualification statute requires a certificate-of-merit expert to possess a current, active license authorizing practice in the defendant's field. Because the plaintiff's expert held inactive or retired licenses when he signed the affidavit and report, the plaintiff did not substantially comply with the certificate-of-merit requirement. The court reversed the denial of summary judgment and remanded for entry of judgment for the defendants.