Ashmead v. Harris

McCORMICK, Justice.

The question here is whether written materials prepared by a liability insurer in a routine investigation following an automobile accident were “prepared in anticipation of litigation” within the meaning of Iowa R.Civ.P. 122(c). We granted interlocutory review of a trial court order compelling their production after holding they were not. Because we disagree with the trial court’s interpretation of the rule, we reverse.

Plaintiffs Del P. Ashmead and Sidney K. Ashmead sued defendant Charles Lloyd Harris for damages they allege they sustained through defendant’s negligence in…