Iowa Court of Appeals Affirms Iowa Workers’ Compensation Commission’s Causation Finding in Favor of Employer

Posted on: October 31st, 2018

For almost 40 years, claimant was employed by the defendant employer, tasked with performing labor intensive job duties including crawling, squatting, kneeling, heavy lifting, and standing. After several years of bilateral knee pain/degeneration, in 2012, claimant underwent a left knee replacement. Claimant alleged that the injury to her knees was the result of a cumulative injury sustained during the course of her employment. The Commission denied benefits based on the fact claimant failed to prove her knee injury arose out of and in the course of her employment. Claimant appealed the Commissioner’s decision.

On September 12, 2018, the Court of Appeals affirmed the Commissioner’s decision. In doing so, the Court referenced the following medical testimony that was offered by defendant employer:

In my opinion, since there is no specific injury that brought on her symptoms, that they are more than likely related to her systematic risk factors such as her age, gender, ethnicity, genetic factors, and possibly dietary factors. It is medically possible that physical activity at work could have played a role in this, but in my medical opinion, that is unlikely. If it did play a role, in my opinion, it would be very minor.

Pursuant to the Court of Appeals decision, this medical testimony sufficiently supported the Commission’s finding that claimant’s injuries were not caused by her employment.

Keeran v. Quaker Oats Co., No. 17-1525 (Iowa App. Sept. 12, 2018).

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