Iowa Workers' Compensation

  Prairie View Management, Inc. v. Moran , No. 22-2023 (Iowa App. Sept. 27, 2023) Claimant emailed her employer with her resignation on December 5, 2019, with the resignation being effective on December 20.  On December 9, she was injured at work.  She submitted a formal letter of resignation a day after the injury, giving the same December 20 end date.  After the injury, claimant's duties were modified.  Claimant testified that she verbally sought to rescind her resignation, but did not file a written resignation.  The employer never offered work to claimant after December 20 and did not pay temporary benefits. The commissioner concluded that claimant was entitled to penalty benefits and temporary total disability benefits, as the employer had never offered work to claimant.  On judicial review, the district court reversed the decision of the agency and concluded that claimant was not entitled to penalty or temporary benefits.  The Court of Appea...

Catholic Health Initiatives v. Hunter , No. 14-0202 (Iowa App. Nov. 26, 2014) involved questions of causation, healing period benefits, permanency benefits and medical care.  The Court of Appeals affirmed the commissioner's award of benefits. Claimant had systemic lupus and was receiving social security disability benefits, but returned to work after those benefits were terminated.  She suffered a traumatic injury to her left wrist, hip and knee, and also complained of headaches as a part of this injury.  Following this incident, claimant had a fall at home and visited the doctor following that fall.  Claimant's symptoms had largely resolved when she slipped and fell again at work on March 3, 2010 (the earlier injuries were in 2009).  She was placed on work restrictions following this fall. Claimant was offered light duty work during the day, but could not perform that work because of family obligations.  No light duty work was available at night. ...

In Schutjer v. Algona Manor Care Center , 780 NW2d 549 (Iowa 2010), the court was faced with four issues: 1) the correct rate; 2) whether TTD and TPD benefits were owed; 3) entitlement to PPD benefits; and 4) penalty. The commissioner had agreed with the employer on all four of these issues, but the district court determined that the rate had been improperly calculated and that the commissioner had incorrectly refused to provide temporary benefits for certain days between 12/2/02 and 1/4/03. In view of the decision on the rate issue, the district court remanded the penalty issue to the commissioner. The court of appeals agreed with the district court insofar as the above items were concerned ( TTD , rate, penalty), but also concluded that the commissioner had not properly analyzed the question of Schutjer's eligibility for temporary benefits after she left work on 1/5/03, and had failed to provide adequate detail concerning the decision that there was no permanent disabil...

On March 5, 2010, the Supreme Court issued a decision in Bell Brothers Heating and Air Conditioning v. Gwinn , 779 NW2d 193 (Iowa 2010). The case involved the proof required by the employee to establish a claim for benefits and expenses on account of medical care obtained by the employee, but not authorized by the employer or the commissioner. Mr. Gwinn had obtained non-authorized care (surgery) a week before the arbitration hearing. The court noted that the employer generally had the right to control care (the so-called authorization defense), but that the statute allowed the employee to choose care in certain emergency situations, when the employer and employee agreed to alternate medical care, and when the commissioner approved alternate medical care. The court concluded, however, that the employer's right to select the medical care did not prevent the employee from choosing medical care at his or her own expense under two circumstances. The first circumstance is when the ...