Cedar Rapids Community School District and EMC Insurance Companies v. Christine Pease
2011 Iowa Sup. LEXIS 103
Iowa2011Background
- Pease injures her right ankle slipping on ice during work as a job coach for the District.
- Parties stipulated a right ankle injury occurred and arose in employment, but disputed nature, scope, and effect of the injury.
- Pease underwent surgeries for ankle injuries and alleges an altered gait caused left ankle and back injuries and worsened depression.
- Independent medical opinions favored causation (Dr. Miller, Dr. Stutts) and vocational impact; medical evidence tied to postaccident impairments.
- District offered defenses challenging causation (Dr. Crowe, Dr. Mease, Dr. Montgomery) and argued limited or no linkage; video surveillance raised credibility concerns.
- Courts below addressed whether substantial evidence supported the commissioner's factual findings; Court vacated Court of Appeals and affirmed District Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of review for medical causation | Pease's case rests on substantial evidence supporting causation | District argues evidence insufficient or improperly weighed | Substantial evidence supports causation; deferential review upheld |
| Left ankle and lower back causation | Dr. Miller's opinions show aggravation by the work accident | Miller relied on disputed history; alternative viewpoints exist | Causation supported by substantial evidence |
| Depression causation | Depression aggravated by work injury per Stutts/Bradley/Brownell | Malingering/preexisting depression questioned; some contradictory testimony | Depression aggravated by work injury supported by substantial evidence |
| De novo review and apportionment | Commissioner properly conducted de novo review; apportionment not preserved | District preserved apportionment error; weight given to evidence contested | De novo review proper; apportionment issue not preserved; permanent total disability affirmed |
| Medical expenses linkage to work injury | Heart symptoms linked to anxiety treatment from work injury | Expenses not clearly causally related | Evidence supports linking heart-related bills to work-related stress/anxiety. |
Key Cases Cited
- Dunlavey v. Econ. Fire & Cas. Co., 526 N.W.2d 845 (Iowa 1995) (medical causation lies in the domain of expert testimony; review deferential to commissioner’s findings)
- Wal-Mart Stores, Inc. v. Caselman, 657 N.W.2d 493 (Iowa 2003) (substantial evidence review requires weighing all relevant evidence)
- John Deere Dubuque Works of Deere & Co. v. Weyant, 442 N.W.2d 101 (Iowa 1989) (substantial evidence standard; not required to adopt all inferences)