Court of Appeals Dismisses Interlocutory Appeal as Moot

H.D. Supply Management v. Smith, No. 23-1656 (Iowa App. Sept. 18, 2024)

In this interlocutory appeal, the parties requested the Court to decide whether a stay of a workers' compensation award was appropriate.  Claimant had filed a request for judgment under 86.42 following the commissioner's finding of permanent total disability.  Defendants moved to stay enforcement, despite the fact they had failed to post a bond in a timely manner.  Ultimately, the district court stayed the order, finding that claimant would  not be prejudiced despite the late posting of the bond. While the appeal was pending, the underlying claim was reversed and remanded to the commissioner (the underlying issue in the case was whether a combined arm and shoulder injury should be treated industrially, which the Supreme Court answered in the negative in Bridgestone Americas v. Anderson, 4 N.W.3d 676 (Iowa 2024).

The parties argued that the case was not moot, given the fact that some benefits would be owed even with the reversal of the underlying decision.  The Court of Appeals concludes that the question of judgment entry was moot, given the district court's reversal of the decision of the commissioner. The Court concludes that even if they agreed a stay should not have been ordered, there was no relief to grant claimant because the stay only operated while the case was pending before the district court. The district court lacks authority to enforce a commissioner's award that no longer exists. 

Claimant also argued that even if the case was moot, the Court should address the underlying question under the public importance exception to the mootness doctrine, because whether injured workers should be "paid benefits which are not contested or disputed during judicial review proceedings" was an issue of public importance that was likely to recur.  On this issue, the Court finds that the issue was not before them in the appeal.  Although the issues raised in the briefing migh recur, "deciding them would provide little new guidance on any important issue" as similar issues had previously been decided by the Supreme Court in Grinnell College v. Osborn, 751 N.W.2d 396 (Iowa 2008).

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