Earlier this year, the Iowa Court of Appeals handed down an important workers’ compensation decision that will likely have an impact on numerous cases going forward. In Plumrose USA and Zurich Ins. Co. v. Hathaway, the Court of Appeals upheld the decision of the Iowa Workers’ Compensation Commission awarding temporary and permanent disability benefits to an employee with a history of knee surgeries after he fell at work and injured his knee.
The employee, who was 57 years old at the time of his work-related injury, worked as a maintenance mechanic. Before his work injury, which occurred in January 2009, he had undergone three surgeries on his right knee. He had also received several steroid injections in the affected knee, and his medical records showed a diagnosis of bone-on-bone arthritis. In January 2009, the employee fell down a flight of exterior stairs that had been washed by another employee and left to freeze over. A doctor diagnosed him with a meniscus tear, ACL tear, and patella tendon tear in his right knee and referred him to an orthopedic surgeon, who recommended a total knee replacement. A doctor who performed an independent medical examination stated that the employee would have needed a total knee replacement regardless of the injury. Based on that doctor’s opinion, the employer denied the employee’s workers’ compensation claim. The workers’ compensation arbitrator determined that the injury was compensable â€“ a decision affirmed by both the commissioner and the district court.
On appeal, the Court of Appeals stated: “While a claimant is not entitled to compensation for the results of a preexisting injury or disease, its mere existence at the time of a subsequent injury is not a defense.” The Court held that the employee proved that his injury occurred in the course of his employment. The fact that his injury was “aggravated, accelerated, worsened, or ‘lightened up'” by a work-related injury did not preclude him from receiving workers’ compensation benefits.
Iowa Workers’ Compensation Law
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