Iowa Supreme Court Casts Doubt on Idiopathic Injury Defense

Posted on: December 7th, 2018

On November 16, 2018, the Iowa Supreme Court issued a ruling concerning the compensability of idiopathic injuries. The case involved a restaurant employee who had a seizure and fell backwards on a level floor while handling a customer’s order. The Commission declined to award benefits on the grounds that, as a matter of law, idiopathic injuries (i.e. injuries due to a personal condition) to level surfaces are not compensable under Iowa law. Claimant appealed.

On appeal, the Iowa Supreme Court reversed and remanded the Commission’s decision, holding that cases involving idiopathic falls should be factually analyzed on a case by case basis. In other words, the Court held that there is no “hard-and-fast rule” that idiopathic falls onto level floors are never compensable. Rather, injured workers have the “burden and the opportunity” to prove that a condition of employment increased the risk of injury.

Jason Bluml v. Dee Jay’s Inc., No. 18-0317 (Iowa Nov. 16, 2018).

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