Iowa Workers' Compensation

In Brinck v. Siouxland Mental Health Center , No. 17-1774 (Iowa App. Sept. 12, 2018), claimant filed a review reopening action alleging that his mental disorder was caused by his earlier work injury.  The commissioner dismissed the action, finding that the mental health problems were not related to the work injury and further concluding that even if they had been related, this had been litigated previously and was barred by res judicata.  The Court of Appeals affirms the decision of the agency. The court begins its opinion by noting that generally speaking, after an employee is awarded benefits for an injury sustained at work, the cause is closed, whether by judicial decision or settlement. Under the review-reopening provisions of the statute, however, the case may be reopened if the claimant demonstrates that the employee's current condition is proximately caused by the original injury. Claimant was a doctor at the mental health facility who fell and hit his head.  A...

In Keeran v. Quaker Oats Co., No. 17-1525 (Iowa App. Sept. 12, 2018), claimant argued that the agency had used an incorrect standard of law in determining whether claimant had suffered knee injuries as a result of her work at Quaker Oats.  The Court of Appeals rejected this argument and an associated argument that the findings of the commissioner were not supported by substantial evidence.  The take nothing opinion of the commissioner was affirmed. The court indicates that to prove an injury arose out of employment, claimant must establish a causal connection between the employment and the injury.  Claimant must also demonstrate that the injury is the proximate cause of the disability.  To do this, a cause must be found to be "substantial."  Citing Ayers v. D & N Fence Co., 731 N.W.2d 11, 17 (Iowa 2007)..  To demonstrate an aggravation, the injury must not have coincidentally happened at work, but must be caused by or related to the working environ...