Lorri Hagen v. Serta/National Bedding Co., LLC, and Safety National Casualty Co.

Summary

The Iowa Supreme Court held that the workers’ compensation commissioner did not abuse his discretion in excluding Lorri Hagen’s untimely expert reports, and therefore reversed the district court’s judgment that had ordered the reports admitted. The court remanded for entry of an order affirming the commissioner’s exclusion decision. The decision rests on the deference owed to the agency under Iowa law and the statutory authority to exclude evidence that would cause unfair prejudice.