Court of Appeals Concludes that Agency Applied the Correct Legal Standard in Determining Causation

In Keeran v. Quaker Oats Co., No. 17-1525 (Iowa App. Sept. 12, 2018), claimant argued that the agency had used an incorrect standard of law in determining whether claimant had suffered knee injuries as a result of her work at Quaker Oats.  The Court of Appeals rejected this argument and an associated argument that the findings of the commissioner were not supported by substantial evidence.  The take nothing opinion of the commissioner was affirmed.

The court indicates that to prove an injury arose out of employment, claimant must establish a causal connection between the employment and the injury.  Claimant must also demonstrate that the injury is the proximate cause of the disability.  To do this, a cause must be found to be "substantial."  Citing Ayers v. D & N Fence Co., 731 N.W.2d 11, 17 (Iowa 2007)..  To demonstrate an aggravation, the injury must not have coincidentally happened at work, but must be caused by or related to the working environment.  The court concluded that the agency correctly stated the standard by indicating that claimant had to demonstrated that the natural degenerative processes were accelerated, speeded up or aggravated by her work activities. The court finds not error in the agency's statement of legal principles.

Claimant also argued that the commissioner's findings on causation were not supported by substantial evidence.  The commissioner accepted the DME of Dr. Gorsche over other medical opinions presented.  The court concludes that the evidence supports the findings actually made by the agency and the dismissal of the claim is affirmed.