Case name: Whirlpool Corp. v. Davis, No. 3-582/12-1962 (Iowa Ct. App. 07/24/13).
Ruling: The Iowa Court of Appeals held that a specialist was entitled to permanent total disability benefits and medical expenses.
What it means: In Iowa, a worker can obtain reimbursement for alternative medical care if he shows that the care was reasonable and beneficial.
Summary: A coding specialist was rolling a drum of chemicals off a wooden pallet when a board on the pallet broke, causing the drum to fall. The specialist tried to hold on to it, but the drum began pulling him. His foot got caught between two slats on the pallet, and he heard a rip in his lower back. He felt severe pain and dizziness. He was diagnosed with a lumbar strain. He continued to have chronic back pain and depression. The specialist sought workers' compensation benefits. The Iowa Court of Appeals held that he was entitled to permanent total disability benefits, medical expenses, and costs.
The court found that the specialist established causation and entitlement to PTD benefits. The court found that his medical condition, chronic pain, and depression combined to preclude him from employment. Two doctors opined that he had a permanent impairment.
The employer asserted that the specialist was not entitled to medical expenses for treatment by a physician that was not his authorized physician. The physician's treatment notes indicated that the treatment addressed the specialist's work-related lower back pain or depression. Therefore, the treatment was reasonable and beneficial. The court found that the specialist was entitled to reimbursement of medical expenses for the treatment.
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October 7, 2013
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