State News : Iowa

NWCDN is a network of law firms dedicated to protecting employers in workers’ compensation claims.

NWCDN Members regularly post articles and summary judgements in workers’ compensations law in your state.  

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Peter v. Paylor, v. Dee Zee Incorporated And Travelers Indemnity Company Of Ct., Court of Appeals of Iowa, No. 14-1570

On November 10, 2010, Claimant, Peter Paylor, suffered a work related injury to his lower back for which he sought medical care on November 12, 2010. Claimant’s employer, Dee Zee Incorporated, stipulated the injury caused temporary disability. Claimant underwent back surgery in April 2011. He claimed the surgery was causally related to the work injury and filed a claim for permanent disability benefits. The employer denied causation and denied Claimant sustained a permanent disability related to his work injury. The deputy commissioner found Claimant did not prove the April 2011 surgery and subsequent treatment were related to his work injury. The commissioner affirmed the decision. The district court affirmed the agency’s action.

On appeal, Claimant contends the agency’s finding that his surgery and subsequent treatment were unrelated to his work injury is not supported by substantial evidence. He contends, for the same reason, the agency’s decision is irrational, illogical, and wholly unjustifiable. 

The Court of Appeals concludes the agency’s decision is supported by substantial evidence and is not irrational, illogical, or wholly unjustifiable. The Court notes that the agency carefully assessed the medical evidence as reflected in Claimant’s medical records and the opinions of different physicians. The agency credited some of the medical professionals’ opinions over others based on their respective training, experience, and area of practice and based on whether the opinions jibed with Claimant’s symptoms. The agency further took into account the quality of the opinion based on the medical history, or lack thereof, Claimant provided to the respective medical professional. 

Medical causation presents a question of fact that is vested in the discretion of the workers’ compensation commission. While there may be evidence in the record contrary to the agency’s findings and conclusions, “[e]vidence is not insubstantial merely because it would have supported contrary inferences.” Wal-Mart Stores, Inc. v. Caselman, 657 N.W.2d 493, 499 (Iowa 2003). The question is not whether the evidence would support a different finding, the question is whether the evidence supports the finding actually made. Accordingly, the Court of Appeals affirms the district court’s decision on judicial review.


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