VOGEL, Presiding Judge.
Mark Madsen and Farner Bocken Company (Madsen) appeal the district court's rulings that admitted medical evidence relating to Carolyn Weddle's future pain and suffering and past medical expenses. Madsen claims the district court erred in overruling his objections to the evidence because Weddle failed to timely disclose the evidence related to future pain and suffering and failed to provide expert testimony on causation regarding her past medical expenses.
I. Background Facts and Proceedings
On June 30, 2014, Weddle filed a petition claiming personal injuries— primarily a broken ankle—as a result of an automobile accident involving Madsen. In July 2014, Madsen served Weddle with discovery interrogatories, which sought, in part, information regarding Weddle's treating physicians, treatment, and any potential expert testimony related to her injuries and treatment. Madsen followed up with requests for production in November 2014. From December 2014 through March 2015, Weddle provided her answers to Madsen's discovery requests, which named Dr. Eric Jensen—a podiatric specialist—as one of her treating physicians. Weddle also provided a medical authorization, which gave Madsen permission to access Weddle's medical records and designated her treating physicians as potential expert witnesses in her supplemented answers. Between March 9, 2015, and the start of trial on November 17, 2015, Weddle failed to further supplement her discovery responses.
In July 2015, Weddle revealed in her deposition that she was still seeing Dr. Jensen every three weeks or so regarding her continued ankle pain related to the accident. The day before trial, on November 16, 2015, Madsen deposed Dr. Jensen, who discussed his treatment of Weddle both before and after March 2015, as well as some of the long-term consequences resulting from her injuries. Madsen filed a motion in limine, which sought to prevent Weddle from presenting evidence on damages that was not timely disclosed as part of her discovery responses. The court and the parties were then able to go through the transcript, line by line to determine where objections had been made.
After a hearing, the district court sustained the motion in limine in part and overruled it in part. The court excluded portions of the deposition testimony that focused on the permanency of, and possible future surgeries from, Weddle's injuries but allowed portions relating to the type of arthritis Weddle suffered from and the pain management treatment that occurred after March 2015 to be read to the jury.
Madsen also objected to Weddle's medical bills being submitted because Weddle did not call an expert to show causation. The district court found there was sufficient evidence to show the nexus between the injury suffered and the subsequent medical bills to submit to the jury and overruled the objection. The jury found in favor of Weddle and awarded her approximately $117,000 in damages, including $65,000 for future pain and suffering and $29,902.73 for past medical expenses. Madsen appeals.
II. Standard of Review
We review a trial court's decisions regarding sanctions for a discovery violation for abuse of discretion. Whitley v. C.R. Pharmacy Serv., Inc., 816 N.W.2d 378, 385 (Iowa 2012). "[W]e will not reverse the court's decision to admit evidence unless the record shows prejudice to the complaining party." Id. We also review the admissibility of evidence for abuse of discretion. Lovick v. Wil-Rich, 588 N.W.2d 688, 692 (Iowa 1999).
III. Future Pain and Suffering Award
On appeal, Madsen claims the district court erred in overruling some of his objections and admitting evidence he claimed supported the award of future pain and suffering damages that was not timely disclosed. Weddle asserts the district court acted within its discretion and Madsen was not prejudiced.
"The discovery process seeks to make a trial into `a fair contest with the basic issues and facts disclosed to the fullest practicable extent.'" Whitley, 816 N.W.2d at 386 (quoting Comes v. Microsoft Corp., 775 N.W.2d 303, 311 (Iowa 2009)). Interrogatories are one method of achieving discovery, and parties are required to respond when served with them, absent an objection. Id. "Additionally, the rules require a party who has responded to an interrogatory to later supplement or amend the response to include information acquired after the initial response was made when, among other circumstances, the question addressed a matter that bore `materially upon a claim or defense asserted by any party to the action.'" Id. (quoting Iowa R. Civ. P. 1.503(4)(a)(3)).
In this case, it is undisputed that Weddle failed to supplement her discovery requests from March 2015 until the time of trial. Accordingly, we agree with the district court Weddle violated discovery rules. The district court sanctioned Weddle by excluding much of the deposition testimony from Dr. Jensen that directly commented on the permanency of her injuries and possible future surgical procedures resulting from ongoing pain. However, the court allowed limited testimony regarding her more specific diagnosis of post-traumatic arthritis from March 2015 until the time of trial:
As to Dr. Jensen's pain management treatment of Weddle post March 2015, the following portion was not objected to:
We do not agree Madsen was prejudiced by the portions of Dr. Jensen's testimony that were a not excluded or not specifically objected to.
Weddle testified extensively about her pain, and physical limitations, including that she expects to have pain the rest of her life. This testimony, on its own, could have reasonably supported the jury's determination of future pain and suffering damages.
Because we conclude that the admitted portions of Dr. Jensen did not opine as to future pain and suffering but that Weddle's testimony did support the jury's award of future pain and suffering damages, we find Madsen was not prejudiced by the admitted portions of Dr. Jensen's testimony and affirm on that issue. See Whitley, 816 N.W.2d at 385.
IV. Medical Expenses
Madsen argues the district court erred in admitting evidence of Weddle's medical expenses because Weddle failed to produce expert testimony that the expenses were incurred from her injuries caused by the accident.
Our supreme court has specifically rejected the imposition of a "requirement for expert testimony in order to establish an element for tort recovery." Roling v. Daily, 596 N.W.2d 72, 75 (Iowa 1999). "[I]t is unnecessary to present expert testimony on causation in those situations in which the subject `is within the common experience of laypersons.'" Estate of Long ex rel Smith v. Broadlawns Med. Ctr., 656 N.W.2d 71, 83 (Iowa 2002), abrogated on other grounds by Thompson v. Kaczinski, 774 N.W.2d 829, 839 (Iowa 2009).
In overruling Madsen's objection, the district court stated:
We agree with the district court's analysis that the testimony about the timeline, circumstances, and events that led to the medical bills supported a finding of causation. Additionally, we note Dr. Jensen testified to the nature of the injuries he observed and the treatments he performed. We conclude the jurors, using their common experience, could have reasonably compared the testimony of the witnesses and concluded the medical bills were caused by the automobile accident. See id. We affirm.
Because we conclude Madsen was not prejudice by the admission of Dr. Jensen's testimony and the district court did not abuse its discretion in admitting evidence of Weddle's medical expenses, we affirm.