Iowa Workers' Compensation

  January 2026 Valtierra v. SIF , No. 23012300.01 (App. Jan. 29, 2026) - In this Fund case, claimant was denied benefits for failure to demonstrate a first injury to the left eye (Christenson). Claimant argues that he presented unrebutted evidence of a 3% injury to the left eye. The commissioner affirms.  The commissioner concludes that in order to demonstrate a first injury to the eye, there must be a showing of a permanent loss of use of the eye. Claimant had a fracture or the orbital wall surrounding the eye, which the commissioner finds had "healed without incident." Claimant's ophthalmologist expressed concerns that claimant's ocular muscles could be entrapped, but noted full range of motion of the eye and good vision.  No restrictions were imposed as a result of the eye injury. Dr. Bansal noted that claimant continued to have headaches and visual disturbances, particularly when looking to the left.  He also noted measurable functional deficits in extraocular mo...

  Towns v. Silver Oaks Nursing and Rehabilitation Center , No. 25-0310 (Iowa App. Dec. 17, 2025) In this somewhat complicated jurisdictional dispute, claimant initially filed an application for alternate medical care, which was denied.  A petition for judicial review resulted in the district court remanding the issue to the agency to redetermine the alternate medical care dispute based on more specific evidentiary findings.  The agency, through a deputy, issued a decision again denying alternate medical care.  Rather than filing an application for judicial review, claimant filed a document captioned "presentment of agency response to remand order for additional factual finding and request for order for hearing transcript and scheduling orders" with the district court. At hearing, defendants challenged jurisdiction, as claimant had not filed a petition for judicial review. Claimant argued the court had retained jurisdiction under its earlier remand order. The court ag...

  US Nursing Corp. v. Decormier , No. 25-0407 (Iowa App. Dec. 3, 2025) Claimant suffered an injury at work.  Under her contract at work, she was initially guaranteed 48 hours of work per week at $65 per hour, with $97.50 overtime.  She received a $10 per hour raise the week before she was injured. The deputy concluded her weekly rate was $1562.50 and denied penalty benefits.  On appeal, the commissioner agreed with the weekly rate but awarded a $5500 penalty.  Defendants filed a judicial review, which affirmed the decision of the commissioner The fighting issue with respect to the rate was whether section 85.36(6) or 85.36(9) was to be applied. The commissioner found that 85.36(6) appied, as claimant had worked at US Nursing for not only ten weeks in Sioux City but on an earlier assignment.  Defendants' argument that 85.36(9) applied because claimant had earned no wages or less than the usual wages customary in the industry was denied, as defendants' own wi...

  Koeller v. Cardinal Logistics Management Corp. , No. 25-0172 (Iowa App. Dec. 3, 2025) Claimant suffered an injury to his shoulder and was found to need a shoulder surgery , which included a distal clavicle excision .  Dr. Bollier , the physician who performed the surgery, provided a 6% permanent impairment rating based on loss of range of motion . No rating was provided for the distal clavicle excision, as Dr. Bollier did not believe this was related to the work injury. Dr. Taylor , claimant's IME physician , provided a 19% upper extremity impairment rating, which included a 10% rating for the distal clavicle excision.  In making this rating, Dr. Taylor indicated he did not use the 10% modifier from Table 16-18 of the AMA Guides because he believed that Table 16-27 was inadvertently listed as one of the tables to which the modifier should be applied.  Dr. Crites performed a record review and also found that the modifier did not apply and gave the full 10% impair...

LaGuerre v. JBS USA Holdings, Inc. , No. 24-2049 (Iowa App. Oct. 29, 2025) Claimant suffered a degloving injury which resulted in skin being grafted from claimant's right thigh to his right arm.  The employer's expert provided claimant a 9% upper extremity impairment despite the fact that the Guides treat a skin injury as an injury to the whole body.  Claimant's expert provided a 7% body as a whole impairment for a class I skin impairment.  The deputy found that claimant had sustained a scheduled injury, but provided a 7% whole body rating as the Guides instructed. The commissioner affirmed, as did the district court. On appeal, claimant argued that the legal question presented to the Court was whether the injury should be considered unscheduled because the Guides rates that impairment as a whole person impairment.  Claimant conceded that earlier precedent supported the deputy's decision to considered the injury a scheduled injury, but argued that the 2017 amendments...

  Culpepper v. CNH Industrial America LLC , No. 24-2040 (Iowa App. Oct. 29, 2025) The agency denied claimant's alleged back pain, rejecting the report of the treating physician and also finding claimant had not provided timely notice of the decision.  On judicial review, the district court reversed both findings and remanded the claim to the agency for further proceedings.  The Court of Appeals affirms the holdings of the district court. Claimant alleged that he suffered a neck injury while at work and alleged injury dates of 6/8/21, 9/3/21 and 10/29/21. Dr. Abernathey, the treating physician, provided statements concerning the injury on three occasions.  In the first two of those statements, which were referenced in the opinion of the deputy, Dr. Abernathey indicated that work activities did not "cause" the work injury.  In the third report, not discussed by the deputy, Dr. Abernathey opined "within a reasonable degree of medical certainty that [Culpepper's] wo...