Key Iowa Workers' Compensation Rulings

Workers' Compensation Case Summaries: Key Iowa Rulings

Navigating workers' compensation claims can be complex, especially when disputes arise regarding the nature of injuries, the adequacy of medical care, or the extent of benefits. At Klass Law Firm, L.L.P., we are committed to providing our clients with the knowledge and resources they need to understand their rights and obligations under Iowa workers' compensation law. Below are summaries of significant case rulings that shed light on various aspects of Iowa's workers' compensation system.

Medical Care Offered by Employer Deemed Unreasonable and Unduly Inconvenient

In Annett Holdings, Inc. v. Roland, the employee, an over-the-road truck driver, injured his elbow and was initially treated in Indiana. The employer required him to relocate temporarily to Des Moines for light duty work and physical therapy. However, after surgery in Alabama near his home, the employer again required him to relocate to Des Moines for therapy provided in a hotel. The employee filed a petition for alternate medical care, arguing that this was unduly burdensome. The Iowa Workers' Compensation Commission granted the petition, and the decision was upheld by the district court and the Court of Appeals. The courts agreed that requiring the employee to travel 897 miles from home for therapy was unreasonable, especially when local treatment was available. This case reinforces that employers cannot compel employees to receive treatment in a manner that imposes undue hardship.

Employer Needs to Provide Clear Notice of Change in Treatment Authorization

In Ramirez-Trujillo v. Quality Egg, LLC, the employee was injured after slipping on an egg at work. The employer authorized treatment up until September 2009 but did not provide clear notice when it stopped authorizing care. The employee incurred additional medical expenses between May 2010 and April 2011, which the employer initially refused to cover. The Iowa Workers' Compensation Commission ruled that the employer was liable for these expenses because it failed to notify the employee that further treatment was unauthorized. The Iowa Supreme Court upheld this decision, stating that employers must provide actual notice when they change or cease treatment authorization, or they remain liable for the costs incurred.

Employer Not Obligated to Pay for IME Obtained Before Employer's Doctor Issues a Rating

In Des Moines Area Regional Transit Authority v. Young, the claimant sought an Independent Medical Examination (IME) before the employer’s doctor provided a permanent impairment rating. The Iowa Supreme Court ruled that the employer was not obligated to cover the cost of the IME, as it was obtained outside the statutory process, which requires the employer's doctor to issue a rating first. This case highlights the importance of following statutory procedures when seeking medical evaluations in workers' compensation cases.

Employer Must Investigate and Notify Before Terminating Benefits

In Pettengill v. American Blue Ribbon Holdings, LLC, the employer terminated benefits without conducting an investigation or providing notice to the employee, who was suffering from a back injury. The Court of Appeals ruled that the employer’s failure to investigate and notify justified penalty benefits. This case emphasizes the employer's obligation to conduct a thorough investigation and notify the employee before terminating benefits.

Injury Sustained While Shopping After Work Still Compensable

In Wal-Mart Stores, Inc. v. Plummer, an employee who had clocked out and was shopping at the store where he worked injured his back while assisting a customer. The employer argued that the injury did not arise out of employment since the employee was off the clock. However, the Iowa Workers' Compensation Commission ruled in favor of the employee, finding that he was still engaged in an act related to his employment when the injury occurred. The Court of Appeals upheld this decision, emphasizing that an employee's actions, even when off the clock, may still be considered work-related if they are within the scope of employment.

Total Knee Replacement Linked to Work Injury

In Case No. 3-1111/13-0495, the employee, who had been informed prior to his injury that he might eventually need a knee replacement, experienced a work-related fall that exacerbated his condition. The employer argued that the knee replacement was not work-related. However, the Iowa Workers' Compensation Commission found that the fall at work significantly worsened the pre-existing condition, making the surgery necessary. The Court of Appeals affirmed this decision, reinforcing that a work injury that exacerbates a pre-existing condition can be compensable.

Credibility Issues Affect Workers' Compensation Claims

In Zaglauer v. Mercy Medical Center, the worker was found not credible due to inconsistencies in her testimony and her failure to disclose prior injuries. The Iowa Workers' Compensation Commission ruled against her, and the decision was upheld by the Court of Appeals. This case underscores the importance of providing accurate and consistent information in workers' compensation claims.

Asthma Due to Workplace Chemicals Not Total Disability

In Deckert v. Jeld-Wen, Inc., the worker developed asthma due to exposure to workplace chemicals but was not deemed totally disabled. The court ruled that the worker was only entitled to a 25% industrial disability because he could still work in environments free of the harmful chemicals. The case illustrates that disability ratings are closely tied to the ability to work in environments other than where the injury occurred.

Offers to Confess Judgment Not Applicable in Workers' Compensation Cases

In a decision involving offers to confess judgment, the Iowa Workers' Compensation Commission ruled that such offers are not applicable in workers' compensation proceedings. The decision, upheld by the Court of Appeals, confirms that the discretion of the Workers' Compensation Commissioner to assess costs cannot be overridden by procedural rules meant for other types of legal cases.

Healing Period Benefits Available After Maximum Medical Improvement

In a landmark decision, the Iowa Supreme Court ruled that healing period benefits could be available even after a claimant reaches Maximum Medical Improvement (MMI). This ruling overturned previous precedent and recognized that a single injury might lead to a new temporary disability, justifying additional benefits even after MMI has been reached.

Suitability of Work Affected by Distance

In a case where an over-the-road truck driver was offered light-duty work 387 miles from home, the Iowa Workers' Compensation Commission determined that the job was not suitable due to the distance. The Supreme Court upheld this decision, recognizing that distance from home and family support can be crucial factors in determining the suitability of work offered to an injured worker.

No Permanent Impairment Awarded Despite Surgery

In a case involving shoulder surgery, the claimant did not receive a permanent impairment award because the Iowa Workers' Compensation Commission found that the surgery did not result in a lasting disability. The Court upheld the decision, noting that the AMA Guides are not the sole determinant of permanent impairment and that other factors, including the ability to engage in employment, must be considered.

Healing Period Benefits Awarded Despite Retirement

In a case where a worker retired shortly after a workplace injury, the Iowa Workers' Compensation Commission awarded healing period benefits. The employer argued that the retirement negated the need for benefits, but the court affirmed the decision, recognizing that the retirement was influenced by the injury.

Iowa Workers' Compensation Jurisdiction Over Maritime Work

In Bluff Harbor Marina v. Wunnenberg, the court ruled that the Iowa Workers' Compensation Commission had jurisdiction over a maritime worker's death, despite the employer's argument that federal law should apply. The decision hinged on the fact that the worker was engaged in routine maintenance, not construction or expansion, which placed the case within Iowa's jurisdiction.

These case summaries provide insight into the complexities of workers' compensation law in Iowa. If you are dealing with a work-related injury, consulting with an experienced Des Moines workers comp attorney or lawyer for personal injury can help ensure that your rights are protected.

For more information or to schedule a consultation, call us at [insert office number] or email us at info@ironcladinjurylaw.com. We are here to assist you with all your workers' compensation needs across Iowa, South Dakota, and Nebraska.

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