The Iowa Supreme Court has generally broadly defined what is considered a work-related injury. For instance, employers or even doctors will often tell an injured worker that, since there was some pre-existing problem before, such as arthritis or a degenerating disc between two vertebrae in the spine, that the condition, which was never painful before, or which is now much more painful, is not work-related. There are two standards for determining whether an injury is related to an event, legal causation and medical causation. Under Iowa law, if a pre-existing condition is made painful, or made worse, by an injury or a repeated activity at work, it is considered work-related, at least to the extent that the work injury or activity made it worse. Also, if it is not possible to determine what part of the condition is work-related, then all of it is considered work-related.
One of the most common forms of injury is a repetitive-use injury, such as developing carpal tunnel syndrome from constantly using one or both hands at work. That is a work-related injury. If a worker develops carpal tunnel. A recent decision of the Iowa Supreme Court, Meyers v. IBP, found that an employee who had worked only two days before developing carpal tunnel syndrome was entitled to compensation by the employer. The Iowa Supreme Court decision reversed the decision of the Iowa Workers’ Compensation Commissione, and made is possible for workers to establish work injuries even though they had worked at that employer only a short time.
A decision of the Iowa Supreme Court, McIlravy v. North River Insurance and Crum & Forster Insurance, filed in October of 2002, set out the Iowa Supreme Court standard for when a workers’ compensation insurance carrier can be held responsible for refusing to provide care for a work injury.
However, the Iowa Court of Appeals recently held, in Ottumwa Regional Health Center v. Mitchell, 752 NW2d 35 (Iowa 2008), that a fall at work was not work-related, because the injured worker could not show that it was due to a wet floor or any other work condition. That decision seems to make no sense; the Court found that, if she had noticed water on the floor, the fall would have been work-related. That suggests that a worker now has a duty to investigate the injury scene immediately after an injury. It also could result in the odd outcome that someone who falls and loses consciousness would not be able to establish a work injury. It is an odd decision, and leads to a clearly unfair outcome, a confusing legal standard, and an excuse for insurance carriers and employers to deny claims on specious grounds. That case is on appeal to the Iowa Supreme Court. It is hoped that they can clarify the standard.
Injuries which occur during employee recreational activities, such as company baseball games are also covered.
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