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.  

Select a state from the dropdown menu below to scroll through the state specific archives for updates and opinions on various workers’ compensation laws in your state.

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Legal Update by Attorney Tyler Smith

Gumm v. Easter Seal Society of Iowa, File No. 18-1051 (Iowa, May 15, 2019)

The issue in this case involved whether a claimant, after sustaining a traumatic, acute injury, is allowed to bring a cumulative injury claim with regard to symptoms/injuries to that same body part. The Court of Appeals addressed the two Supreme Court of Iowa cases that have addressed acute-then-cumulative injury claims: Ellingson v. Fleetguard (requiring claimant to show a “distinct and discreet” disability/injury as a result of cumulative work duties) andFloyd v. Quaker Oats (allowing a cumulative injury claim in the certain circumstance where the claimant had not been compensated via an award, volunteered benefits, etc. and doing so was unavailable due to the statute of limitations). In this case, the Court of Appeals reversed and remanded the Commissioner’s finding that the claimant failed to establish a distinct and discreet disability/injury underEllingson. The Court of Appeals extended/expanded the Floyd case in holding that if a claim relating to the first injury is barred by the statute of limitations (regardless of whether benefits had been paid with regard to the initial acute injury), a cumulative injury claim can be made for the increase in disability brought on by subsequent work duties. Appellees have filed Applications for Further Review.



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Peddicord Wharton Legislative Updates are intended to provide information on current developments in legislation impacting our clients. Readers should not rely solely upon this information as legal advice. Peddicord Wharton attorneys would be pleased to answer any questions you may have about this update. ©2019 Peddicord Wharton. All Rights Reserved.