Iowa Workers' Compensation

In Janssen v. Merry Lanes , No. 15-1511 (Iowa App. Sept. 14, 2016), the Court of Appeals upheld the determination by the commissioner that claimant's injury was to the leg and not the body as a whole.  Claimant suffered an injury to her hamstring while working as a bartender.  The deputy concluded that claimant's injury extended to the body as a whole and awarded permanent total disability benefits.  The commissioner reversed, concluding that claimant's injury was a scheduled member injury to the leg and awarding 72.6 weeks of benefits. Claimant argued that the essence of prior court decisions was that the nerves and veins were system wide injuries which extended beyond a scheduled member.  In support of this assertion, claimant cited Collins v. IDHS , 529 N.W.2d 627 (Iowa App. 1995) and First Fleet Corp. v. Hannam , No. 14-1254 (Iowa App. July 9, 2015).  The court in Janssen reads Collins  as not reaching the question of whether reflex sympathetic dystro...

In Linden v. Tyson Foods, Inc. , No. 14-0141 (Iowa App. Oct. 1, 2014), claimant suffered a comminuted fracture to her elbow.  Claimant argued that the injury had also affected her shoulder and should have been treated as an industrial injury.  The agency found that there was only a scheduled member injury and the district court affirmed, finding that the situs of the injury was the anatomical location of the physical damage or derangement. Without a great deal of discussion, the court concludes that the agency correctly interpreted the law with respect to when a scheduled member can be deemed to extend to the body as a whole.  The court further found that substantial evidence supported the agency's finding that claimant's complaints of pain in her shoulder were not due to her work accident.  The court concluded that it was within the agency's prerogative to weigh the evidence on these issues and concluded that substantial evidence supported the conclusion reached b...