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Timothy Floyd Clites v. State of Iowa
Iowa Court of Appeals
322 N.W.2d 917 (1982)
Timothy Floyd Clites’s (plaintiff) father filed a lawsuit against the state of Iowa (defendant) for negligently treating Timothy with tranquilizers and physical restraints while he was confined at Glenwood Hospital-School (the hospital), a residential facility for individuals with intellectual disabilities. Timothy was diagnosed with an intellectual disability in early childhood and was admitted to the hospital when he was 11 years old. Seven years after his admission, the hospital began treating Timothy with tranquilizers for a period of five years. The long-term drug use caused Timothy to suffer serious side effects, including uncontrollable facial and body movements. Additionally, Timothy became aggressive and was no longer able to dress himself, comb his hair, brush his teeth, make his bed, and his psychological state and intelligence deteriorated. Timothy’s father filed suit after the Iowa State Appeal Board failed to rule on his claim for damages. The trial court found that the hospital acted negligently in administering tranquilizers to Timothy and awarded damages for future medical expenses and pain and suffering. The hospital appealed the decision, arguing that the court’s negligence finding was erroneous because the court applied the incorrect standard of care regarding the use of tranquilizers and informed consent. The hospital also argued that the damages award was excessive.
Rule of Law
Holding and Reasoning (Snell, J.)
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