Supreme Court Concludes That When Medical Causation is Established, The Legal Causation Factor in Mental Injuries is Met When There is an Unexpected or Unusual Event Without Regards to the Claimant's Own Particular Duties
Tripp v. Scott Emergency Communication Center , No. 21-0841 (Iowa June 3, 2022) Mental injuries in the workers' compensation context have long been treated differently than physical injuries despite the fact that the statute does not explicitly create such a distinction. In Dunlavey v. Economy Fire & Casualty Co. , 526 N.W.2d 845 (Iowa 1995), the Court concluded that mental injuries that did not involve a physical component were compensable under the statute. The Court, however, concluded that a claimant must demonstrate both medical causation and "legal causation." The latter phrase requires an employee to show that the mental injury resulted from "workplace stress of greater magnitude than the day-to-day mental stresses experienced by other workers employed in the same or similar jobs, regardless of employer." In Brown v. Quik Trip , 641 N.W.2d 725 (Iowa 2002), the Court relaxed the legal test in situations where the claimant's mental injury was ...