Iowa Workers' Compensation

In Hendrickson v. Ihle Trucking, Inc. , No. 13-1114 (Iowa App. April 16, 2014), the court of appeals affirmed the commissioner's finding that claimant's injury was limited to his right hand.  The court first noted that its review of final agency action was "severely circumscribed" and stated that nearly all disputes are won or lost at the agency level.  Citing Pease  and House. The Court of Appeals noted that the district court had appropriately discussed and considered the evidence and affirmed the commissioner's decision that the injury was limited to the right hand.  The court noted that it could not improve upon the district court's analysis, which found that the agency's decision was detailed and exhaustive.  Based on the district court's decision, the court affirmed, citing Iowa Ct. R. 21.26.

In Horn v. Cummins Filtration-Lake Mills , No. 1300351 (Iowa App. Nov. 6, 2013), the Court of Appeals affirmed a decision awarding claimant the 6% impairment rating found by Dr. Kuhnlein, for an injury to the arm.  Three impairment ratings were presented at hearing, a 10% rating from Dr. Formanek, a 12% rating from Dr. Adams and a 6% rating from Dr. Kuhnlein.  The deputy awarded the 6% rating.  Claimant filed a rehearing application contesting that the deputy had used the wrong legal standard and noting that numerous aspects of the AMA Guides  were "faulty and unscientific."  The rehearing petition was not answered and was deemed denied.  The ruling was affirmed on appeal. On rehearing at the commissioner level, claimant argued that the determination of functional disability was not merely related to the impairment ratings.  The rehearing application was denied, and indicated that the arguments of counsel had been considered prior to the rendering of...