Iowa Workers' Compensation

Thomas v. Archer Daniels Midland Company , No. 23-0323 (Iowa App. Nov. 8, 2023) Claimant initial suffered a compensable injury to his right eye in 2017.  He subsequently sustained several injuries in 2018 while stepping off a pontoon boat, which he attributed to a lack of depth perception as a result of his eye issues.  The deputy ruled in favor of claimant, but the commissioner reversed, finding that the 2018 injuries were not a sequelae of the original eye injuries.   The Court of Appeals concluded that the decision of the commissioner was supported by substantial evidence and affirmed the decision of the commissioner.  The Court noted that medical causation was a question of fact vested in the commissioner's discretion and noted that although claiant speculated that his fall was caused by his right eye injuries, claimant could not specifically recall what happened and there were no witnesses to provide context.  The speculation of medical experts that vi...

Knaeble v. John Deere Dubuque Works , No. 21-1934 (Iowa App. Nov. 17, 2022) Claimant suffered three injuries while working for John Deere - one to his right leg and left foot in 2014, a second to his hands and finger in 2017 and a third to his shoulder in 2017.  On the 2014 petition, claimant was awarded a 30% industrial award.  A second petition against the Fund was consolidated with the third petition against the employer.  The deputy concluded that claimant had an 85% industrial loss for the first and second injuries and that the industrial loss for the third injury was 5%.  The deputy determined that the industrial disability for all three injuries was 92%.  The commissioner affirmed the 85% industrial loss.  Contrary to the decision of the deputy, however, the commissioner found that the employer only owed 5% industrial disability due to the shoulder injury.  The deputy found that Deere was responsible for a combined industrial disability of 35% (...

  Harrell v. Denver Findley & Sons, Inc. and Second Injury Fund , No. 21-0827 (Iowa App. July 20, 2022) In this action, the deputy originally concluded that claimant was permanently and totally disabled with respect to the SIF.  The deputy found that under 85.34(2)(x), the Fund was not entitled to a credit because of a prior left knee surgery, the only evidence of which was raised at hearing by claimant, who noted that he had previously had a left total knee replacement.  No medical evidence or rating was provided concerning this injury.  On appeal, the commissioner found that the Fund was entitled to the credit, based on his own reading of the AMA Guides.  The commissioner reduced the permanent total disability award to 75% despite the fact that the parties had not raised this as an issue. On judicial review, the district court found that the Fund was entitled to credit, but remanded the case to the agency, finding that the commissioner should not have modi...