Court of Appeals Affirms 35% Award With Minimal Analysis

Polaris Industries v. Quastad, No. 15-1572 (Iowa App. Aug. 17, 2016) represents the latest Court of Appeals decision to note that the scope of review on appeal is limited, and that the commissioner's decision can only be reversed if that decision is illogical, irrational or wholly unjustifiable.  The court affirms a 35% industrial disability award and notes that there can be a diminution of earning capacity even when there has not been a diminution in actual earnings, citing ABF Freight Systems, Inc. v. Veenendaal, No. 11-1862, 2012 WL 186033, at *4 (Iowa App. May 23, 2012).

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