Court of Appeals Affirms Award of Industrial Disability and Penalty Benefits

Masterbrand Cabinets v. Simons, No. 20-1635 (Iowa App. Sept. 22, 2021) 

The commissioner concluded that claimant had suffered a ruptured right quadriceps tendon, concluded that this injury extended into the body, specifically the hip and awarded industrial disability benefits as well as penalty.  Defendants appealed and the district court affirmed the decision of the commissioner. 

On appeal, the Court of Appeals noted that defendants' argument that claimant's injury was a scheduled injury was a "miserly reading of the statute."  The court noted that if an injury to a scheduled member has effects extending beyond that member, resulting in permanent impairment to the body as a whole, this may be the basis of industrial disability.  The court concludes that the commissioner did not err in interpreting the law in finding that the injury extending into the body as a whole. The court also concludes that the commissioner's findings were supported by substantial evidence.  Specifically, the court concluded that the reports of three doctors identified an impairment of hip resulting from his torn quadriceps tendon.  Accordingly, the decision of the commissioner was affirmed.

Although the court notes in its introduction to the case indicated that defendants had appeal the award of penalty benefits, there is no specific discussion of this aspect of the case in the court's decision.