Iowa Workers' Compensation

  Klein v. Whirlpool Corp. , No. 25-0458 (Iowa App. Jan. 7, 2026) The fighting issue in this case is whether a distal clavicle excision is to be rated in full or to be reduced based on a modifier.  In the case, claimant's IME doctor concluded the modifier did not apply under the Guides.  Defendant's doctor did not rate the distal clavicle excision at all, rating the shoulder only on the basis of loss of motion.  The agency concluded that in an earlier decision (Jay v. Archer Skid Loader Service), the modifier had been used even though no doctor had used this.  In that case, according to Jay, it was the agency's duty to calculate ratings in accordance with the AMA Guidelines.  In this case, the commissioner found that the agency must determine whether the rating was in compliance with the AMA Guides.  The District Court affirmed the decision of the agency, finding that the agency's interpretation of the Guides did not qualify as prohibited usage of agen...

  January 2026 Valtierra v. SIF , No. 23012300.01 (App. Jan. 29, 2026) - In this Fund case, claimant was denied benefits for failure to demonstrate a first injury to the left eye (Christenson). Claimant argues that he presented unrebutted evidence of a 3% injury to the left eye. The commissioner affirms.  The commissioner concludes that in order to demonstrate a first injury to the eye, there must be a showing of a permanent loss of use of the eye. Claimant had a fracture or the orbital wall surrounding the eye, which the commissioner finds had "healed without incident." Claimant's ophthalmologist expressed concerns that claimant's ocular muscles could be entrapped, but noted full range of motion of the eye and good vision.  No restrictions were imposed as a result of the eye injury. Dr. Bansal noted that claimant continued to have headaches and visual disturbances, particularly when looking to the left.  He also noted measurable functional deficits in extraocular mo...