Norie C. Smith v. TPI Iowa, LLC and Insurance Company of the State of Pennsylvania, 20-1269

Smith worked at TPI Iowa assembling wind-turbine blades (repetitive fiberglass work); she reported left shoulder pain allegedly from a 2014 workplace fall in a December 2015 claim.
MRI in 2016 showed a rotator cuff tear; Smith saw several orthopedists and eventually underwent rotator-cuff surgery in October 2016.
Dr. Steven Aviles (consulted early) and Dr. Patrick Sullivan (treating surgeon who performed surgery) both declined to attribute the shoulder injury to Smith’s work.
Dr. Jacqueline Stoken (independent examiner) opined the impairment was causally connected to the “subject injury,” but did not state the injury was caused by Smith’s employment or her repetitive job duties.
The workers’ compensation commissioner found Smith failed to prove her injury arose out of employment; the district court affirmed on judicial review.
On appeal, the Court of Appeals affirmed, holding substantial evidence supports the commissioner’s factual findings and credibility assessments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Smith proved her shoulder injury "arose out of" employment (causation)	Smith: repetitive work caused the shoulder injury/rotator cuff tear	TPI: treating and consultative experts found no work causation; claimant’s testimony insufficient	Court: Affirmed—claimant failed to prove causation; substantial evidence supports commissioner’s finding
Whether the commissioner’s decision should be reversed as not supported by substantial evidence or irrational application of law	Smith: decision lacks substantial evidence and is irrational under Iowa Code § 17A.19 grounds	TPI: factual determinations and credibility are for the commissioner and are supported by record	Court: Affirmed—defer to commissioner on factual findings; application of law to facts not irrational or arbitrary

Brewer-Strong v. HNI Corp., 913 N.W.2d 235 (Iowa 2018) (chapter 17A judicial-review principles and agency deference)
Schutjer v. Algona Manor Care Ctr., 780 N.W.2d 549 (Iowa 2010) (no deference to legal interpretation; deference to agency factual findings)
St. Luke’s Hosp. v. Gray, 604 N.W.2d 646 (Iowa 2000) (worker must prove injury arose out of and in course of employment; causation typically requires expert testimony)
Quaker Oats Co. v. Ciha, 552 N.W.2d 143 (Iowa 1996) (definition of "in the course of" employment)
Larson Mfg. Co. v. Thorson, 763 N.W.2d 842 (Iowa 2009) (agency application of law to facts overturned only if irrational or wholly unjustifiable)