920 N.W.2d 82
Iowa2018Background
- Jason Bluml, a Long John Silver’s shift manager with a known seizure disorder, suffered a seizure at work on Feb. 15, 2012, fell backward and struck his head on the restaurant’s ceramic tile floor, sustaining serious brain injuries.
- Bluml had been noncompliant with antiseizure medication and had alcohol issues prior to the incident; the seizure was unrelated to work (an idiopathic fall).
- Bluml sought workers’ compensation benefits; the deputy commissioner and the Iowa Workers’ Compensation Commissioner denied benefits, adopting a view that idiopathic falls to level surfaces are generally not compensable.
- The district court affirmed the commissioner. Bluml appealed to the Iowa Supreme Court, which retained the appeal.
- The central factual/legal question: whether an idiopathic fall directly to a level (hard) floor can “arise out of” employment under Iowa Code § 85.3(1), analyzed under Iowa’s increased-risk standard from Koehler Electric.
- The Supreme Court reversed and remanded, holding that whether a workplace condition (e.g., hardness of the floor) increased the risk of injury is a factual question for the commissioner, not a legal categorical bar.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether idiopathic falls onto level floors can be compensable | Bluml: increased-risk test (Koehler) allows recovery if workplace condition (hard tile) increased injury risk | Employer: majority rule—idiopathic falls to level surfaces (hard floors) are not compensable as a matter of law | Court: No categorical rule; compensability depends on factual showing that employment conditions increased the risk of injury |
| Proper standard to apply to idiopathic falls | Bluml: apply increased-risk test—employment need only contribute to hazard | Employer: treat level-floor falls as legally noncompensable regardless of floor hardness | Court: reaffirmed Koehler’s increased-risk test for idiopathic falls; factual inquiry required |
| Whether commissioner’s decision denying benefits was reviewable de novo or factual-substantial-evidence | Bluml: commissioner mischaracterized a factual issue as legal; claim requires fact finding | Employer: commissioner’s legal interpretation was persuasive; district court deferred | Court: legal interpretation reviewed for errors of law; factual findings receive deference—here commissioner erred by resolving a factual question as law |
| Burden of proof on remand | Bluml: claimant should have opportunity to prove increased-risk by employment condition | Employer: argued precedents support legal bar so burden cannot be met | Court: claimant retains burden to prove employment increased risk; commissioner must re-evaluate facts under increased-risk standard |
Key Cases Cited
- Koehler Elec. v. Wills, 608 N.W.2d 1 (Iowa 2000) (adopts increased-risk test for compensability of idiopathic falls)
- Miedema v. Dial Corp., 551 N.W.2d 309 (Iowa 1996) (no recovery absent proof that employment exposed claimant to increased risk)
- Meyer v. IBP, Inc., 710 N.W.2d 213 (Iowa 2006) (applies Koehler increased-risk concept to repetitive-stress manifestation)
- Lakeside Casino v. Blue, 743 N.W.2d 169 (Iowa 2007) (discusses actual-risk test for non-idiopathic falls; does not overrule Koehler for idiopathic falls)
- Maroulakos v. Walmart Assocs., Inc., 915 N.W.2d 432 (Neb. 2018) (recent analogous Nebraska decision stressing need for factual support to invoke increased-risk rule)