Court of Appeals Addresses Issues Involving Requests for Admission
In Lynn v. Pella Corp., No. 12-1506 (Iowa App. July 24, 2013), the court addressed issues involving IRCP 1.510, which governs requests for admissions. The court concluded that when a party objected to a request for admission, the objecting party was only required to state their objection, and not to admit or deny the request.
Claimant filed a workers' compensation claim, and on February 16, 2010, filed a request for admissions. Hearing had been set for April 7, 2010. Defendants objected, stating that the admissions requests were untimely under the hearing assignment order. Hearing was held on April 7, and the decision concluded that the objections were sufficient and were not deemed admitted. The deputy also concluded that claimant failed to establish an injury arising out of and in the course of employment, which, not coincidentally, was the subject of the request for admissions. The commissioner affirmed, citing IRAP 1.510, which requires that a party must move to determine the sufficiency of answers if they believe the admissions have not been answered in a satisfactory manner.
On judicial review, the district court concluded that because Pella failed to deny or state why it could not respond to the requests for admission within 30 days, the requests were deemed admitted. According to the court, the burden was on Pella to obtain a ruling on this question, not on Lynn. The appellate court seemingly had little difficulty in concluding that a party who objects to a request for admission need only state the reasons for the objection. The court notes that rule 1.510 provides that the party who has made the request "may move to determine the sufficiency of the answers or objections." The court rejected claimant's argument that Pella needed to file an answer and an objection, and noted that the burden was on the moving party to move for a determination of the sufficiency of the objection. Since claimant failed to do so, the objection to the request for admission stood, and there was no deemed admission.
Claimant filed a workers' compensation claim, and on February 16, 2010, filed a request for admissions. Hearing had been set for April 7, 2010. Defendants objected, stating that the admissions requests were untimely under the hearing assignment order. Hearing was held on April 7, and the decision concluded that the objections were sufficient and were not deemed admitted. The deputy also concluded that claimant failed to establish an injury arising out of and in the course of employment, which, not coincidentally, was the subject of the request for admissions. The commissioner affirmed, citing IRAP 1.510, which requires that a party must move to determine the sufficiency of answers if they believe the admissions have not been answered in a satisfactory manner.
On judicial review, the district court concluded that because Pella failed to deny or state why it could not respond to the requests for admission within 30 days, the requests were deemed admitted. According to the court, the burden was on Pella to obtain a ruling on this question, not on Lynn. The appellate court seemingly had little difficulty in concluding that a party who objects to a request for admission need only state the reasons for the objection. The court notes that rule 1.510 provides that the party who has made the request "may move to determine the sufficiency of the answers or objections." The court rejected claimant's argument that Pella needed to file an answer and an objection, and noted that the burden was on the moving party to move for a determination of the sufficiency of the objection. Since claimant failed to do so, the objection to the request for admission stood, and there was no deemed admission.
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