Iowa Workers' Compensation

  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 ...

  Jackson v. Bridgestone Americas Tire Operations , No. 21-0017 (Iowa App. Dec. 15, 2021) Claimant's estate alleged that he committed suicide as a result of a mental injury arising out of his employment.  The agency and district court denied benefits.   Claimant was a 28 year employee at Bridgestone and he missed only three days of work in those 28 years.  In August of 2016, claimant engaged in acts of insubordination (disobeying supervisory directives concerning safety and quality) and lying about those acts.  He was suspended for a cooling off period.  He was subsequently called into a meeting and was told he was being fired.  Claimant went home and was found in the garage with his vehicle running.  At that point, he agreed to come out, but he left the home and was found dead by hanging a few hours later.  Claimant had made statements at the time that he would take his life if he lost his job. Approximately eight months before his deat...

In Dubinovic v. Des Moines Public Schools , No. 18-0194 (Iowa App. May 15, 2019), the Iowa Court of Appeals affirmed a decision finding that claimant had not demonstrated a mental/mental injury under Dunleavy   and Brown  v. Quik Trip.  Claimant had argued that the Supreme Court's standard in Dunleavy was inconsistent with the workers' compensation law.  The court declines to address this issue, as they are not in a position to overrule existing precedent.  The court finds that the agency correctly held that claimant had not met the Dunleavy standard. The court also addressed the question of whether claimant had demonstrated he met the Brown  standard, which does not require a showing of additional stress if there is an event of a sudden traumatic nature precipitating the mental injury.  The court found that substantial evidence supported the agency's finding that there was no such traumatic event.  The court also found that the failure to ...

Village Credit Union v. Bryant , No. 11-1499 (Iowa App. May 23, 2012), involved the question of whether a claimant who had been held up at gunpoint on two occasions, had established a mental/mental injury and thus was entitled to temporary benefits (the issue of permanency was not before the court in this proceeding).  Claimant was understandably upset by the events at work, and Dr. Jennisch concluded that she suffered from post-traumatic stress disorder and should work for an employer where she had scheduled appointments rather than random encounters with individuals off the street. Claimant found a job following the robberies with another employer, but had an anxiety attack shortly after beginning work, and quit that employment.  The deputy concluded, under Brown v. Quik Trip Corp., 641 N.W.2d 725 (Iowa 2002), that claimant had been subjected to events of a sudden, traumatic nature that led to unusual stress, and thus had a compensable mental/mental injury.  The de...