Iowa Court of Appeals Affirms Summary Judgment Ruling Against Claimant in Bad Faith Claim
In Saltern v. HNI Corporation and Gallagher Bassett Services , No. 18-1748 (Iowa App. Oct. 9, 2019), the Court of Appeals affirmed a district court ruling dismissing a bad faith claim brought by plaintiff Saltern. The ruling was premised on the court's conclusion that the employer did not lack a reasonable basis for denying benefits and thus the first prong of the bad faith test was not met. Claimant had prevailed in her workers' compensation claim on her claim for injury due to carpal tunnel syndrome. Penalty was awarded based on the fact that HNI had not communicated its basis for rejecting the claim under section 86.13 of the Code. Following the resolution of the workers' compensation claim, Saltern brought a bad faith action. The district court concluded on summary judgment that at the time that HNI first denied the claim, there was no information to indicate that her carpal tunnel was related to employment. Specifically, no doctor had concluded that the injury