Supreme Court of Iowa

Leroy Eldon Cole v. Southeast Iowa Orthopaedics and Sports Medicine, PC; MGM Healthcare; Midwest Geriatric…

May 8, 2026

Summary

The Iowa Supreme Court reversed the district court’s order compelling arbitration and remanded, holding that Iowa’s arbitration‑specific waiver test requiring prejudice is preempted by the Federal Arbitration Act and that Arbor Court implicitly waived its contractual right to arbitrate through its conduct in litigation.