Mike Brooks, Inc., and Great West Casualty Co. v. James David House
2014 Iowa Sup. LEXIS 21
| Iowa | 2014Background
- James David House, a commercial truck driver, slipped on ice at work on March 7, 2007, and developed a lumbar disc herniation treated with epidural injections, later discectomy (Jan. 31, 2008) and two-level fusion (Nov. 2008).
- House reported ongoing back pain after the March 2007 event, had intermittent symptom flare-ups (including a January 4, 2008 episode when pushing a door), and underwent multiple MRIs showing progression at L4–5.
- Treating surgeon Dr. Hatfield and independent examiner Dr. Kuhnlein both opined the March 7, 2007 slip-and-fall was a substantial cause of House’s continuing back problems and surgeries; Dr. Hatfield later wrote his records related House’s lumbar changes to the March 2007 incident.
- A deputy commissioner and then the Iowa Workers’ Compensation Commissioner found the March 7, 2007 work incident caused House’s disability and awarded permanent total disability benefits; the district court affirmed.
- The Iowa Court of Appeals reversed, finding insufficient evidence linking the March 2007 event to the ultimate disability and emphasizing gaps about the January 4, 2008 incident; the Supreme Court granted further review.
- The Iowa Supreme Court vacated the court of appeals decision and affirmed the district court, holding the commissioner’s causation finding was supported by substantial evidence when the record is viewed as a whole.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was House’s permanent total disability causally connected to the March 7, 2007 work injury? | House: medical opinions (treating and IME) show the March 2007 incident was a substantial contributing cause of all subsequent back problems and surgeries. | Brooks: evidence does not support causation; January 4, 2008 event may be a separate intervening injury and treating notes did not reference that incident. | Held: Commissioner’s finding of causation is supported by substantial evidence and must be upheld. |
| Could the commissioner credit experts who lacked knowledge of the Jan. 4, 2008 episode? | House: Commissioner may credit the experts’ opinions (Hatfield, Kuhnlein) given their exams and record reviews. | Brooks: Experts’ opinions are unreliable if they lacked critical facts about the 2008 incident. | Held: Even if Hatfield was unaware of the door incident, the commissioner reasonably credited Kuhnlein’s thorough IME and other records; weight of evidence supports causation. |
| Standard of review — is medical causation a fact question entitled to deference? | House: applies statutory substantial-evidence standard; deference to commissioner’s factual findings. | Brooks: urges closer scrutiny given alleged evidentiary gaps. | Held: Medical causation is a factual question; court defers and will affirm if substantial evidence supports the commissioner. |
Key Cases Cited
- Finch v. Schneider Specialized Carriers, Inc., 700 N.W.2d 328 (Iowa 2005) (commissioner has discretion to make factual determinations)
- Cedar Rapids Cmty. Sch. Dist. v. Pease, 807 N.W.2d 839 (Iowa 2011) (substantial-evidence standard; deference to commissioner on expert credibility)
- Watson v. Iowa Dep’t of Transp., 829 N.W.2d 566 (Iowa 2013) (appellate review under Iowa Code chapter 17A)
- Deaver v. Armstrong Rubber Co., 170 N.W.2d 455 (Iowa 1969) (credibility and acceptance of expert opinion within commissioner’s province)
- Sherman v. Pella Corp., 576 N.W.2d 312 (Iowa 1998) (consideration of all evidence bearing on causal connection)
- Drake Univ. v. Davis, 769 N.W.2d 176 (Iowa 2009) (permanent total disability benefits not subject to apportionment)