Rojas, et al. v. Pine Ridge Farms, L.L.C., No. 08-0554 (Iowa 03/05/10).
Ruling: The Iowa Supreme Court ruled that Iowa's workers' compensation law requiring a 50 percent reduction in compensation benefits to nonresident alien beneficiaries was constitutional.
What it means: In Iowa, when a deceased worker leaves a surviving spouse, that spouse is entitled to receive the deceased's compensation to the exclusion of actual dependents who otherwise may have been eligible to receive benefits. Where there are dependent children, however, the benefits will be equitably apportioned between the surviving spouse and the children.
Summary: The alleged dependents of a deceased employee -- the spouse and one child living in the United States and five children and their mother living in Mexico -- claimed they were entitled to compensation after the employee's death. They also claimed the apportionment of benefits among eligible beneficiaries was incorrectly calculated between the American family and the nonresident alien family. The Iowa Supreme Court determined that even though the Mexican mother was eligible as an actual dependent, she was not entitled to compensation because the surviving spouse receives full compensation under Iowa law. The court noted that the deceased was married to the Mexican mother in a religious ceremony, which is not recognized under Mexican or Iowa law. The court also rejected the Mexican mother's arguments that an Iowa law requiring a 50 percent reduction of a nonresident alien dependents' benefits, with the other 50 percent payable to the Second Injury Fund, was unconstitutional. The court remanded the case for the workers' compensation commissioner to apportion the benefits equitably between the American surviving spouse and the six children.
The court explained that equitable distribution of benefits does not mean equal distribution. The equitable distribution includes consideration of the relevant facts and the needs of the dependents to make distribution fair to all concerned.
The Mexican mother and children also alleged they were entitled to equal protection of the law because their claims were derivative of the deceased worker's right to benefits which arose out of his employment. The Iowa Supreme Court rejected their claims, holding that not only were they not entitled to equal protection of the law as nonresident aliens, their claim for benefits was an independent claim and was not derivative of the deceased's right to benefits.
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April 19, 2010
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