Case name: Martinez Construction v. Ceballos, No. 3-152/12-1514 (Iowa Ct. App. 06/12/13).
Ruling: The Iowa Court of Appeals held that a worker was entitled to benefits for his injuries in a fall.
What it means: In Iowa, expert medical opinion evidence is not required to establish causation.
Summary: A worker for a construction company was standing on a roof when he lost his footing as he attempted to jump into a forklift basket. As he was landing, he hit his face and right shoulder, and twisted his left knee. He was knocked unconscious and was transported to the hospital. Hospital records showed that he suffered four broken ribs and a perforated lung. When he was discharged from the hospital, he was restricted from lifting more than 10 pounds. Later, he complained of difficulty lifting his right shoulder and problems with his left knee. X-rays revealed that his shoulder was dislocated and he had fluid in his knee. The worker sought workers' compensation benefits. The Iowa Court of Appeals held that he was entitled to benefits.
The company argued that there was no expert medical opinion testimony to establish causation. The court found that expert witness evidence, although typically necessary to establish causation, is not required to establish causation in every workers' compensation case. Here, the worker said that he did not suffer pain or difficulty moving his shoulder or knee before his fall. His injuries required one week of hospitalization. Three months later, the worker sought treatment on his own because he experienced difficulty moving his shoulder and knee. The court pointed out that there was no evidence suggesting that he suffered an intervening injury.
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August 19, 2013
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