Iowa Workers' Compensation

Kollasch v. Hormel Foods , No. 13-1416 (Iowa App. April 16, 2014), addresses issues raised by section 86.42 of the Iowa Code.  Claimant filed for judgment based upon an agreement for settlement.  At hearing, claimant objected to the introduction of what he believed was extrinsic evidence outside of the agreement of the parties.  The district court summarized the parties views about the meaning of several key terms in the agreement, specifically regarding visits to a pharmacy.  Claimant filed a motion to reconsider, arguing that the district court had made findings of fact and strayed from the terms of the settlement agreement.  The court also found that the evidence produced by defendants was meant to clarify and not modify the settlement. Claimant argued before the Court of Appeals that the district court erred in making findings of fact, in construing the term reimburse, in entering a money judgment for expenses already incurred and in not awarding costs. ...

Claimant was a carpenter who started doing carpentry work for Stark Construction when he had an injury.  When he reached the hospital, claimant indicated he was employed by Don Risdahl Builders and was self-employed.  Claimant later filed a claim against Stark, who affirmatively alleged that he was an independent contractors.  The deputy found claimant was an independent contractor and the commissioner reversed.  At the district court level, the court reversed the agency, finding that claimant was an independent contractor. The Court of Appeals reversed the action of the district court and affirmed the action of the commissioner in Stark Contruction v. Lauterwasser , No. 13-0609 (Iowa App. April 16, 2014).  Initially, the court found that since the law did not vested the agency with power to interpret the term "employee," no deference was due the commissioner in determining how the term was to be defined.   On appeal, claimant contended that the dist...

The Court of Appeals, in Cargill Meat Solutions v. DeLeon , No. 13-1266 (Iowa App. April 16, 2014), once again concludes that factual findings are left to the commissioner, and affirms an award of permanent total disability benefits.  The court adopted the conclusions of the district court, which had noted that the commissioner credited the views of Dr. Hines in finding permanent total disability. The court addressed defendants' argument that Dr. Hines was not provided with all prior medical treatment records, and that therefore the decision should be reversed under the Court of Appeals' decision in Mike Brooks, Inc. v. House .  The court noted that evidentiary rulings were in the commissioner's discretion and that a scrutinizing analysis was not to be given to decisions of the agency on factual matters.  The court also noted that the Supreme Court had vacated the decision in House , upon which Cargill had relied.  The court found that the commissioner had consider...

In Hendrickson v. Ihle Trucking, Inc. , No. 13-1114 (Iowa App. April 16, 2014), the court of appeals affirmed the commissioner's finding that claimant's injury was limited to his right hand.  The court first noted that its review of final agency action was "severely circumscribed" and stated that nearly all disputes are won or lost at the agency level.  Citing Pease  and House. The Court of Appeals noted that the district court had appropriately discussed and considered the evidence and affirmed the commissioner's decision that the injury was limited to the right hand.  The court noted that it could not improve upon the district court's analysis, which found that the agency's decision was detailed and exhaustive.  Based on the district court's decision, the court affirmed, citing Iowa Ct. R. 21.26.