Court of Appeals Affirms Reversal of Agency Denial of Benefits
In Cozad v. Russell Corp. , No. 1-864 (Iowa App. Jan. 19, 2012), the Court of Appeals issued an interesting decision affirming a decision of the district court, which had reversed the agency action denying benefits. The remarkable aspect of this decision is the fact that Cozad was decided only weeks after the Supreme Court's decision in Pease , in which the court had indicated its reaffirmance of the importance of substantial evidence in workers' compensation cases. Cozad involved a fairly straightforward back injury, in which the claimant reported an acute injury at work. She had previously had a significant history of back problems, but all of the doctors who opined on the issue of causation found that the injury arose out of and in the course of employment and caused a permanent impairment. The agency found that claimant had suffered only a temporary impairment as a result of the injury. The decision was based on the fact that the doctors who opined on cau...