P.M. Lattner Manufacturing Co. and Accident Fund General Insurance Co. v. Michael Rife

Summary

The Iowa Supreme Court held that under Iowa Code §85.34(7) the employer is liable only for the marginal increase in functional impairment caused by the second injury, requiring a remand for additional evidence on the prior impairment, and affirmed the commissioner’s reimbursement of the full independent medical examination cost as reasonable. It reversed the district court’s judgment and remanded for further proceedings.