Court of Appeals Affirms Denial of Benefits on Substantial Evidence Grounds

 Spence v N&L Parkison Trucking, Inc., No. 23-0144 (Iowa App. Oct. 25, 2023)

Claimant filed a workers' compensation claim alleging that he suffered a shoulder injury at work.  The doctors who he saw related to the injury found that claimant had a rotator cuff injury, but noted claimant had related them to the pain in his shoulder from an earlier two weeks earlier.  An IME related claimant's injury to the work events and provided him with a 12% impairment to the body as a whole as a result of the injury.  The deputy found claimant was not credible in part due to his past crimes of dishonesty and denied benefits and the commissioner affirmed.  The district court affirmed the decision of the agency.

The Court of Appeals rejected claimant's argument that the decision of the commissioner was not supported by substantial evidence.  The Court noted that due regard must be given to the commissioner discretion to accept or reject testimony based on witness credibility.  The district court had noted four reasons claimant had been found not credible, which the Court of Appeals finds accurately reflected what claimant had told his doctors at the time.  Claimant argued that the evidence from the medical opinions in the record finding that claimant's injuries were work-related were unrebutted.  The Court rejected this argument, finding that although these opinions were unrebutted, they noted specifically that this was premised on the belief that the history provided by the claimant was accurate.  "Because the commissioner found Spence lacked credibility in presenting his injury history to the diagnosing physicians, the commissioner was not obligated to accept the medical causation opinions."  Although the commissioner had also noted that defendants' witnesses were not credible, since claimant had the burden of proof, defendants had no burden to prove some other cause of claimant's injury.

The Court affirmed the decision of the agency based on substantial evidence.

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