Court of Appeals Affirms Denial of Workers' Compensation Benefits; Rules on Credit Issue

Thomas v. Archer Daniels Midland Company, No. 23-0323 (Iowa App. Nov. 8, 2023)

Claimant initial suffered a compensable injury to his right eye in 2017.  He subsequently sustained several injuries in 2018 while stepping off a pontoon boat, which he attributed to a lack of depth perception as a result of his eye issues.  The deputy ruled in favor of claimant, but the commissioner reversed, finding that the 2018 injuries were not a sequelae of the original eye injuries.  

The Court of Appeals concluded that the decision of the commissioner was supported by substantial evidence and affirmed the decision of the commissioner.  The Court noted that medical causation was a question of fact vested in the commissioner's discretion and noted that although claiant speculated that his fall was caused by his right eye injuries, claimant could not specifically recall what happened and there were no witnesses to provide context.  The speculation of medical experts that vision loss caused the fall was not enough to establish medical causation, because neither expert stated this was a likely cause of the fall.

The second issue presented involved a credit question.  The commissioner credited ADM's overpayment of temporary disability and healing period benefits for the 2018 injury against payment of claimant's partial disability for the 2017 injury.  Citing Deutmeyer, claimant argued that the credit against future injuries provided in 85.34(5) must be applied to all overpayments of benefits.  The Court rejected this argument, noting that Deutmeyer only addressed the overpayment of permanent partial disability benefits, not temporary or healing period benefits.  The Court concludes that reading 85.34(5) to apply to all workers' compensation benefits would render section 85.34(4) superfluous (85.34(4) applies to credits against future permanent partial disability benefits and specifically includes overpayments of healing period or temporary benefits).  The Court rejected claimant's credit claim and affirmed the decision of the commissioner.