Court of Appeals Affirms Commissioner's Decision Finding that Claimant's Mental Health Issues Arose Out of Employment

In Menard, Inc. v. Schneberger, No. 14-0682 (Iowa App. Feb. 11, 2015), the Court of Appeals affirmed the decision of the commissioner concluding that claimant's mental health problems arose out of and in the course of his employment.  At the commissioner level, the employer stipulated to a physical injury to the shoulder, but denied that claimant's panic attacks and depression were related to the work injury.  Dr. Seamands, claimant's doctor for her psychological problems, noted that claimant had not had any history of depression other than situational depression under acute stressors.

Claimant met with Dr. Donald Gammel for an evaluation requested by the employer.  Dr. Gammel was an occupational health doctor and he opined that the psychological difficulties were not related to the work injury.  He stated that the depression was a normal and expected manifestation of a preexisting disorder.  Dr. Seamands indicated that claimant did not have a preexisting condition of panic disorder or depression and found that the work injury had substantially aggravated and led to these disorders.  Dr. Seamands also noted that claimant was likely to need therapy for these disorders for the foreseeable future and found that claimant was unable to work.

John Brooke, Ph.D., provided an opinion for the employer that support linking claimant's depression and panic disorder to the work injury was "scant at best."  At hearing, a psychiatrist, Dr. Terry Davis, also testified.  Dr. Davis found that claimant had a somatoform disorder, which was not caused or aggravated by the work injury.  The deputy rejected Dr. Davis' testimony, finding that he had no idea of the legal standard of causation.  The deputy found the opinions of Dr. Seamands well-reasoned and based on actual treatment.  Ultimately the deputy found permanent total disability, On appeal, the commissioner concluded that the opinions of Dr. Seamands were the most persuasive and rejected the opinions of the other doctors who had opined on the issue.

At the district court level, the court found that claimant's mental health injury arose out of and in the course of employment, based on substantial evidence standards.  The court remanded the case on the permanent total disability finding, however, concluded that the commissioner did not set forth facts to support this conclusion.  This finding was apparently not the subject of a cross-appeal at the appellate level.

The Court of Appeals first noted the "the deference we afford to decisions of administrative agencies largely controls our result today."  The court stated that medical causation is generally proven with expert testimony and found that the decision whether to accept or reject medical testimony was within the peculiar province of the commissioner.  The Court of Appeals stated that "to grant the relief requested by Menard's we would have to step into the shoes of the commissioner, which we cannot do."  The court affirmed the decision of the agency, and remanded the case to the agency for further opinion on the permanent total disability issue.

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