Rhonda Baldwin, as of the Estate of Garrett O. Baldwin v. Central Iowa Hospital Corp., d/b/a Iowa Methodist Medical Center

── Rhonda Baldwin, as of the Estate of Garrett O. Baldwin v. Central Iowa Hospital Corp., d/b/a Iowa Methodist Medical Center ── Court: Supreme Court of Iowa Date: May 22, 2026 Category: General In the Iowa Supreme Court No. 24–1645 Submitted January 20, 2026—Filed May 22, 2026 Rhonda Baldwin, as executor of the Estate of Garrett O. Baldwin, Appellee, vs. Central Iowa Hospital Corp., d/b/a Iowa Methodist Medical Center, Appellant. Appeal from the Iowa District Court for Polk County, Coleman McAllister, judge. Interlocutory appeal from the denial of a motion for summary judgment on a wife’s claims for vicarious liability based on the alleged negligence of a nurse, direct negligence in retaining that nurse, emotional distress damages, and punitive damages following her husband’s death. Reversed and Case Remanded. McDonald, J., delivered the opinion of the court, in which all justices joined. Jeffrey R. Kappelman (argued), Erik P. Bergeland, Peter R. Lapointe, and Joseph F. Moser of Finley Law Firm, P.C., Des Moines, for appellant. Gary Dickey (argued) and Matthew Sahag of Dickey, Campbell, & Sahag Law Firm, PLC., Des Moines, for appellee.  2 McDonald, Justice. Plaintiff Rhonda Baldwin, individually and as executor of the Estate of Garrett Baldwin, brought this suit against nurse Andrea Cline and Central Iowa Hospital Corp. d/b/a Iowa Methodist Medical Center arising out of the death of her husband. This appeal arises from the district court’s denial of the hospital’s motion for summary judgment. At issue in this appeal are the following questions: (1) whether the plaintiff’s claim for negligent retention and supervision is barred because it is not disputed that the hospital is vicariously liable for the alleged negligence of its employees; (2) whether the summary judgment record shows there is a triable issue of fact with respect to Rhonda’s request for bystander emotional distress damages; and (3) whether the summary judgment record shows there is a triable issue of fact on the plaintiff’s request for punitive damages. Our review is for the correction of errors at law. Kostoglanis v. Yates, 956 N.W.2d 157, 158 (Iowa 2021). I. The summary judgment record, when viewed in the light most favorable to the plaintiff, shows the following. Garrett Baldwin presented to the emergency room on March 26, 2021, with abdominal pain. Physicians diagnosed him with acute pancreatitis without infection or necrosis, and he was admitted to the Iowa Methodist Medical Center (IMMC) for continued care. Baldwin’s condition did not improve, and he was transferred to the critical care unit at IMMC. As a result of Baldwin’s declining renal function, he was started on Continuous Renal Replacement Therapy (CRRT), a form of continuous dialysis. The CRRT was administered through a catheter inserted into Baldwin’s jugular vein. Baldwin remained in the critical care unit for the next several days.  3 Nurse Andrea Cline was on Baldwin’s critical care team. On April 11, she was responsible for checking the CRRT tubing and monitoring Baldwin. The CRRT tubing was supposed to be, but was not, secured with a Luer lock. A Luer lock is a standardized, threaded, and secure connection system used to join small fluid fittings to ensure they do not become disconnected. On the morning of April 11, Cline did not document in Baldwin’s chart that the tubing connections were secure; the inference being that Cline did not check to ensure that the tubing connections were secure. At some point during that morning, Cline, in an effort to move some of the CRRT tubing out of the way, fastened the CRRT tubing to Baldwin’s bed railing using a tourniquet tied too tightly or a clip that was too small to allow slack in the tubing. Later that afternoon, Baldwin asked