Iowa: Severe Back Injury Helping Friend Was Medically Tied to Earlier Admitted Industrial Injury

An Iowa employer is responsible for paying indemnity and medical benefits related to a serious back injury sustained by an employee while helping a friend move go-kart frames onto a trailer since substantial evidence indicated that six weeks earlier the employee sustained an admitted lower back injury, the employee returned to work after a brief period of time, and medical experts indicated that the second injury was the direct and natural result of the original injury. The appellate court disagreed in relevant part with the employer’s contention that the go-kart incident was an intervening and superseding cause of the second injury. Helping the friend was not rash activity, but the sort of activity common in life. The court approved of the commissioner’s reference to Larson’s Workers’ Compensation Law, § 10.01, et seq., which generally states that where an accident occurs to an employee in the usual course of his employment, the employer is liable for all consequences that naturally and proximately flow from the accident.

Thomas A. Robinson, J.D., the Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is the co-author of Larson’s Workers’ Compensation Law (LexisNexis).

LexisNexis Online Subscribers: Citations below link to Lexis Advance. Bracketed citations link to lexis.com.

See Carl A. Nelson & Co. v. Sloan, 2015 Iowa App. LEXIS 1138 (Nov. 25, 2015) [2015 Iowa App. LEXIS 1138 (Nov. 25, 2015)]

See generally Larson’s Workers’ Compensation Law, § 10.01 [10.01]

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law.

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