Supreme Court of Iowa

Dee A. Delaney v. Second Injury Fund of Iowa

May 10, 2024

Summary

The court held that the workers’ compensation commissioner applied an erroneous per se rule by treating every vascular-system injury as an unscheduled whole-body injury. Whether an injury affects a scheduled member or the body as a whole must instead be determined factually on a case-by-case basis, and a scheduled-member injury remains potentially qualifying even when it also causes a sequela injury elsewhere. The court vacated the court of appeals decision, reversed the district court judgment, and remanded for further proceedings.