Court of Appeals Affirms District Court Judgment Enforcing Workers' Compensation Commissioner's Decision

 Reinsbach v. Great Lakes Cooperative, No. 20-1097 (Iowa App. Sept. 22, 2021)

In this action to enforce the decision of the commissioner under section 86.42, claimant argued that the district court went beyond construing the ruling of the commissioner and improperly modified the ruling. The case had previously reach the Court of Appeals with a decision issued on July 9, 2015.  That case found that claimant's condition was related to the work injury, but reversed with respect to the costs of Dr. Kuhnlein's costs. 

The agency subsequently order defendants to provide all future care and treatment recommended by Dr. Strothman.  Claimant sought to enforce that order under 86.42.  Defendants argued that the district court should construe the commissioner's order to provide claimant with all causally related, reasonable and necessary care for the work condition.  The district court ordered care with Dr. Strothman and added that defendants should authorize and pay for all reasonable and necessary future care and treatment.  Claimant appealed to the Court of Appeals.

Citing Rethamel v. Havey, the court noted that the district court is bound to enter judgment in conformance with the workers' compensation award.  The court has no authority to change, reverse or modify the award in an 86.42 proceeding.  In this case, claimant argued that the district court's order making the award subject to the provisions of chapter 85 created ambiguity and also asserted that the words "reasonable and necessary" were superfluous and created uncertainty.  The court rejected both claims, finding that the reference to chapter 85 simply indicated that this was the section of the code governing workers' compensation claims and further finding that the "reasonable and necessary" limitation had be recognized by the commissioner.  Claimant's appeal was rejected and the decision of the district court affirmed.