Court of Appeals Concludes that Agency Correctly determined that Claimant's Mental Health Disorder was not Caused by his Earlier Work Injury

In Brinck v. Siouxland Mental Health Center, No. 17-1774 (Iowa App. Sept. 12, 2018), claimant filed a review reopening action alleging that his mental disorder was caused by his earlier work injury.  The commissioner dismissed the action, finding that the mental health problems were not related to the work injury and further concluding that even if they had been related, this had been litigated previously and was barred by res judicata.  The Court of Appeals affirms the decision of the agency.

The court begins its opinion by noting that generally speaking, after an employee is awarded benefits for an injury sustained at work, the cause is closed, whether by judicial decision or settlement. Under the review-reopening provisions of the statute, however, the case may be reopened if the claimant demonstrates that the employee's current condition is proximately caused by the original injury.

Claimant was a doctor at the mental health facility who fell and hit his head.  A settlement agreement was reached in the underlying action which was premised on a closed head injury, posttraumatic seizure disorder and depressive disorder.  Following the settlement in November of 2012, claimant voluntarily admitted himself to the hospital in November of 2013 indicating that he was a danger to himself or others.  Some fairly out of the ordinary thoughts were noted in the hospital records, including the fact that claimant believed a chip had been implanted in his brain.  He subsequently filed for review-reopening.

Defendants argued that claimant knew of the conditions at the time he entered into the settlement.  The agency found that claimant failed to demonstrate that the psychosis was related to work and also found that the earlier settlement was res judicata.  The Court of Appeals indicates that their determination was largely shaped "by the deference we are statutorily obligated to afford the agency." The agency had relied on Dr. Gutnik, who found that the psychosis could not be related to the work injury.  This, according to the court was substantial evidence supporting the conclusions of the agency.  Although there was no question a different conclusion could have been drawn, this did not mean that there was not substantial evidence supporting the decision. 

On the res judicata question, the court noted that claimant knew about his delusions and thought insertion for a number of years before November of 2013.  Furthermore, claimant had  unsuccessfully attempted suicide shortly after his injury without bringing this to the attention of his doctors and could have brought this up earlier.  Having failed to do so, his claim was barred by res judicata.

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