William Joseph Reinsbach v. Great Lakes Cooperative and Nationwide Agribusiness, 20-1097

Reinsbach injured his lower back at work in 2005; conservative care continued and an additional injury occurred in 2006 during therapy.
A 2008 settlement fixed a 15% permanent partial disability rating and reserved entitlement to future medical care; pain persisted and Reinsbach later sought review/reopening leading to multiple surgeries.
A deputy found Reinsbach’s condition had deteriorated and ongoing treatment was causally related to the work injury; a subsequent deputy affirmed and ordered employer to pay medical bills and IME costs.
On agency appeal and judicial review, this court (in a prior opinion) upheld causation but remanded for allocation of IME costs related to report preparation.
The commissioner’s May 2013 decision ordered reimbursement of past expenses and directed the employer to provide ‘‘all future care and treatment modalities’’ recommended by Dr. Strothman and the Institute for Low Back and Neck Care.
Reinsbach sought district-court judgment to enforce that agency order; the district court entered judgment adding the phrases "subject to the provisions of Iowa Code chapter 85" and limiting future care to "reasonable and necessary" modalities. Reinsbach appealed that wording.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court exceeded its authority under Iowa Code § 86.42 by altering the commissioner’s award language	Reinsbach argued the court’s added wording ("subject to Iowa Code chapter 85" and omission/insertion of qualifiers) created ambiguity or altered the award	Respondents argued entry was improper only if it changed the substance; if judgment entered, it should be construed consistent with chapter 85 to require causally related, reasonable, necessary care	Court held the district court did not err — it construes the commissioner’s decision and properly included the "reasonable and necessary" limitation and the statutory caveat; no modification occurred
Whether the phrase "reasonable and necessary" in the district judgment impermissibly changed the commissioner’s order	Reinsbach contended the phrase was superfluous and created uncertainty by narrowing the commissioner’s directive	Respondents maintained the limitation is implied by the commissioner’s express finding that prior care "was reasonable and necessary" and thus consistent to carry forward	Court held phrase was not superfluous; commissioner had expressly found prior care "reasonable and necessary," and district court properly reflected that limitation in judgment

Rethamel v. Havey, 679 N.W.2d 626 (Iowa 2004) (district court must enter judgment conforming to workers’ compensation award and may not modify it)
Rethamel v. Havey, 715 N.W.2d 263 (Iowa 2006) (district court’s role on judgment is limited to construing the commissioner’s award)
Downs v. A & H Constr. Ltd., 481 N.W.2d 520 (Iowa 1992) (workers’ compensation is purely statutory)
Heartland Specialty Foods v. Johnson, 731 N.W.2d 397 (Iowa Ct. App. 2007) (workers’ compensation statutes are construed to benefit workers where the statute permits)