Charles R. Coffey v. Mid Seven Transportation Company and Great West Casualty Company
2013 Iowa Sup. LEXIS 55
| Iowa | 2013Background
- Coffey, a Mid Seven driver, sustained a work injury in 1994 from a truck accident and PPS; the award covered healing period, disability, medicals, and mileage.
- Coffey and employer/insurer later entered third-party settlements offsetting some benefits; Coffey received net third-party proceeds.
- The arbitration award established Coffey’s entitlement to 375 weeks of PPD and medical expenses; third-party recoveries affected employer credit under §85.22(1) and anticipated offset.
- Coffey filed a petition for review-reopening under §85.26(2) seeking more benefits, medical expenses, and a calculation of credit.
- The deputy commissioner held Coffey’s review-reopening timely status as to medical expenses but untimely for additional weekly benefits; the commissioner affirmed on appeal.
- This appeal interleges the timing of the limitations period, the causal connection for medical expenses, and the calculation/collection of unpaid benefits and credits upon remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When does the §85.26(2) limitations period start? | Coffey contends last payment date should be after offset; credit affects start. | Mid Seven argues start is the arbitration award date. | Remanded to determine last weekly payment date and appropriate start of limitations. |
| Are certain medical expenses causally connected to work injury? | Coffey bears burden to prove work-related causation. | Commissioner reasonably limited to proven causally connected expenses. | Affirmed for the connected expenses; remand for remaining determinations. |
| What is the proper total due under arbitration and how to apply third-party credits? | Coffey seeks full unpaid amounts plus proper credit. | Mid Seven argues credits offset most or all obligations. | Remanded to compute unpaid amounts, credits, and enforcement method; authorize potential compel-payment if needed. |
Key Cases Cited
- Beier Glass Co. v. Brundige, 329 N.W.2d 280 (Iowa 1983) (limitations when only medical Benefits awarded; start from arbitration or filing)
- Ewing v. Allied Const. Servs., 592 N.W.2d 689 (Iowa 1999) (attorney fees via periodic payment method with third-party settlements)
- Waldinger Corp. v. Mettler, 817 N.W.2d 1 (Iowa 2012) (no interpretive authority to agency for statutory interpretation)
- NextEra Energy Res. LLC v. Iowa Utils. Bd., 815 N.W.2d 30 (Iowa 2012) (agency interpretation reviewed for reasonableness; not irrational)
- Rethamel v. Havey, 679 N.W.2d 626 (Iowa 2004) (enforcement of workers’ compensation award via judgment)
- 2800 Corp. v. Fernandez, 528 N.W.2d 124 (Iowa 1995) (substantial evidence standard in agency review)