Court of Appeals Affirms District Court Decision Denying Judgment to Claimant

Kollasch v. Hormel Foods, No. 13-1416 (Iowa App. April 16, 2014), addresses issues raised by section 86.42 of the Iowa Code.  Claimant filed for judgment based upon an agreement for settlement.  At hearing, claimant objected to the introduction of what he believed was extrinsic evidence outside of the agreement of the parties.  The district court summarized the parties views about the meaning of several key terms in the agreement, specifically regarding visits to a pharmacy.  Claimant filed a motion to reconsider, arguing that the district court had made findings of fact and strayed from the terms of the settlement agreement.  The court also found that the evidence produced by defendants was meant to clarify and not modify the settlement.

Claimant argued before the Court of Appeals that the district court erred in making findings of fact, in construing the term reimburse, in entering a money judgment for expenses already incurred and in not awarding costs.  As an initial matter, the COA found no problems with the background portion of the district court, in which the court summarized the arguments of the parties.

Under 86.42, the court must enter a judgment in conformance with the workers' compensation award.  Where the district court merely explains what is in the award, but does not alter the terms of the award, there is no error.  The court may construe the award, but not expand upon it.  The court found that the settlement agreement, which delineated "the pharmacy" at which prescriptions would be picked up meant a particular pharmacy.  Similarly, in construing the term "reimburse," the district court did not err in finding that this meant repayment of a cost incurred.  The court also found that the district court did not err in converting owed expenses from prior visits to the pharmacy to a judgment.  The COA also concluded that there was no error in refusing to assess court costs against Hormel.