Bruce Baker v. bridgestone/firestone and Old Republic Insurance
872 N.W.2d 672
| Iowa | 2015Background
- On May 23, 2010 Bruce Baker suffered a work-related back injury at Bridgestone/Firestone, reported it, and initially received only conservative treatment from the plant physician while continuing to work.
- Pain persisted and escalated over months; diagnostic imaging and specialist care (pain management) occurred later in 2010–2012; Bridgestone paid medicals but discontinued payment on May 23, 2012, asserting the two-year statute of limitations had run.
- Baker filed workers’ compensation petitions on June 20, 2012; the deputy commissioner and the commissioner found the claim time-barred and held the discovery rule does not apply to injuries from a single traumatic event.
- The district court reversed, holding the discovery rule can apply to single-event workplace injuries and remanded to the agency to decide whether it extended Baker’s filing deadline.
- The Iowa Supreme Court affirmed the district court, holding the discovery rule applies to singular-event injuries and remanding for the commissioner to determine if Baker met the discovery-rule standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the discovery rule apply to workers’ compensation claims arising from a single traumatic event? | Baker: discovery rule tolls limitations until claimant knows or should know the nature, seriousness, and probable compensable character of the injury. | Bridgestone: discovery rule categorically does not apply to injuries from a single traumatic event; limitations run from the event. | The discovery rule can apply to single-event injuries; statute runs when claimant knows or should know the nature, seriousness, and probable compensable character. |
| Whether the commissioner correctly relied on Clark (agency precedent) to bar discovery-rule application here | Baker: Clark is inapposite; Clark involved a different limitations trigger (weekly benefits paid) and different facts. | Bridgestone: agency precedent supports barring discovery-rule application to traumatic events. | Court: agency precedent not binding; Clark involves different statutory context and does not control. |
| Standard for when limitations begin under Iowa Code §85.26 | Baker: limitations tolled until nature/seriousness/probable compensability are known or should have been known. | Bridgestone: limitations should start at the date of accident if pain was immediate. | Court: limitations start when claimant knows or should know the nature, seriousness, and probable compensable character (Orr/Herrera standard). |
| Application to Baker’s record (whether claim is timely as a matter of law) | Baker: factual record supports tolling past two years because early treatment was minimal and he continued to work. | Bridgestone: early reporting and treatment put Baker on notice of a compensable injury. | Court: not decidable as a matter of law on this record; remand required for commissioner to apply discovery-rule fact inquiry. |
Key Cases Cited
- Orr v. Lewis Cent. Sch. Dist., 298 N.W.2d 256 (Iowa 1980) (adopted discovery rule for §85.26: limitations run when claimant knows nature, seriousness, and probable compensable character)
- Otis v. Parrott, 8 N.W.2d 708 (Iowa 1943) (earlier rule measuring limitations from the accident; overruled in part by Orr)
- Dillinger v. City of Sioux City, 368 N.W.2d 176 (Iowa 1985) (applied discovery rule to single-event back injury where claimant did not recognize seriousness until later)
- Herrera v. IBP, Inc., 633 N.W.2d 284 (Iowa 2001) (clarified "seriousness" means awareness that condition may have permanent adverse impact on employment)
- Swartzendruber v. Schimmel, 613 N.W.2d 646 (Iowa 2000) (applied discovery-rule analysis; claim barred where medical diagnosis and referral gave notice)
- Larson Mfg. Co. v. Thorson, 763 N.W.2d 842 (Iowa 2009) (reaffirmed discovery-rule formulation tying "permanent adverse impact" to the three-element test)
- Bergen v. Iowa Veterans Home, 577 N.W.2d 629 (Iowa 1998) (discussed statutory measurement of limitations when weekly benefits are paid)
- Mousel v. Bituminous Material & Supply Co., 169 N.W.2d 763 (Iowa 1969) (applied pre-1977 statute to bar late claim from single event; distinguished post-amendment law)