Court of Appeals Reverses Commissioner's Summary Judgment Decision in Favor of SIF
Stowe v. Second Injury Fund of Iowa , No. 16-0599 (Iowa App. Jan. 25, 2107) presented the somewhat unusual situation where the commissioner had disposed of a case on summary judgment grounds. Claimant had settled her case against the employer on an agreement for settlement and in the settlement documents had indicated that the injury was an injury to the left thumb. When claimant brought an action against the Fund, the Fund filed for summary judgment, claiming that an injury to the thumb was not a qualifying injury for SIF purposes. The deputy and commissioner agreed and the case was dismissed. Claimant filed a petition for judicial review and the district court reversed the decision of the agency, finding that the commissioner erred in ruling as a matter of law the settlement agreement precluded claimant from seeking Fund benefits on the basis of a hand injury. The court noted that the Fund was not a party to the settlement agreement and also found there was n...