Court of Appeals Affirms Denial of Penalty Benefits
Cochran v. Quest Liner, Inc. , No. 21-0288 (Iowa App. Jan. 12, 2022) Claimant suffered an injury at work and was paid healing period benefits for a time. Defendants sent claimant a notice that healing period benefits would be ended as required by section 86.13. Claimant alleged that he was entitled to additional healing period benefits and the arbitration decision found that claimant was entitled to continuing healing period benefits. Penalty benefits were denied as the commissioner indicated it was reasonably debatable whether claimant was entitled to continuing benefits. Claimant appealed, arguing that defendants failed to obtain an impairment rating or do any further investigation to determine if he was entitled to further benefits after their authorized treating physician placed him at MMI. On appeal, the court finds that the issue raised implicates the application of law to fact standard of review and that the decision will only be overturned if the a...