Deanna Jo Ramirez-Trujillo v. Quality Egg, L.L.C., Wright County Egg Division, and Selective Insurance Company of America, 2016 Iowa Sup. LEXIS 45

Background

Employee Deanna Ramirez-Trujillo injured her back at work on Aug. 1, 2009; employer Quality Egg acknowledged compensability and authorized care through Sept. 30, 2009.
After Sept. 30, 2009, Ramirez-Trujillo sought additional treatment (May 2010–Apr. 2011), including surgeries; employer disputed it had authorized that later care and disputed causal connection to the Aug. 2009 work injury.
Deputy commissioner found care after Sept. 30, 2009 was not causally related to the workplace injury and denied benefits; the commissioner affirmed causation finding but awarded reimbursement for May 2010–Apr. 2011 medical expenses because employer failed to notify employee it was no longer authorizing care under Iowa Code § 85.27(4).
District court reversed part of the commissioner’s decision, concluding the commissioner misinterpreted § 85.27(4); the court of appeals reinstated the commissioner on that point; both parties sought further review.
Iowa Supreme Court declined deference to the commissioner on § 85.27(4), construed the statute, adopted an objective, multi-factor test to permit an employer to avoid liability in limited circumstances, and remanded for findings on whether the employee knew or reasonably should have known authorization had ended.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of employer liability for care it authorizes under Iowa Code § 85.27(4)	Employer must pay for authorized care until it notifies employee termination; no causation proof required for reimbursement of authorized care.	Employer should not be liable for post-authorization care that is unrelated to the compensable injury or that it did not intend to continue to authorize.	Employer generally liable for authorized care until it notifies employee otherwise; liability limited to care related to the condition forming the compensation claim.
Whether employee must prove causation to obtain reimbursement for authorized care	Ramirez-Trujillo: no causation proof required once employer chose care.	Quality Egg: later care was not causally related and thus not employer’s responsibility.	Court: § 85.27(4) does not require employee to prove medical causation to recover authorized-care costs; but employer may avoid liability in narrow circumstances.
Whether employer can avoid liability despite failing to give statutory notice	Employee: failure to notify means employer remains liable.	Employer: can avoid liability if a reasonable employer would have known employee continued seeking care; employee should check authorization.	Court: employer can avoid liability only by proving employee knew or reasonably should have known care was unauthorized or unrelated; adopted objective multi-factor test to evaluate that knowledge.
Standard of review / deference to commissioner on statutory interpretation	Commissioner’s interpretation should control.	Court should independently interpret § 85.27(4).	Court: no clear legislative delegation to commissioner on this provision; court reviews statute de novo and substitutes its judgment.

Key Cases Cited

R.R. Donnelly & Sons v. Barnett, 670 N.W.2d 190 (Iowa 2003) (discusses employer’s right to choose care and its limits)
Bell Bros. Heating & Air Conditioning v. Gwinn, 779 N.W.2d 193 (Iowa 2010) (explains employer’s qualified right to choose care and related protections)
Lakeside Casino v. Blue, 743 N.W.2d 169 (Iowa 2007) (defines compensable injury as arising out of and in course of employment)
Iowa Ins. Inst. v. Core Grp. of Iowa Ass’n for Justice, 867 N.W.2d 58 (Iowa 2015) (addresses agency deference and statutory interpretation)
Griffin Pipe Prods. Co. v. Guarino, 663 N.W.2d 862 (Iowa 2003) (states workers’ compensation statutes are construed to benefit workers)
Baker v. Bridgestone, 872 N.W.2d 672 (Iowa 2015) (discusses balance of employer control and employee protections under § 85.27(4))
Cedar Rapids Cmty. Sch. Dist. v. Pease, 807 N.W.2d 839 (Iowa 2011) (explains weight of medical expert testimony and commissioner’s factfinding)
Westling v. Hormel Foods Corp., 810 N.W.2d 247 (Iowa 2012) (notes chapter 17A standards govern judicial review of commissioner decisions)