Justin Loew v. Menard, Inc., and XL Insurance America

CourtSupreme Court of Iowa
DecidedFebruary 9, 2024
Docket22-1894
StatusPublished

This text of Justin Loew v. Menard, Inc., and XL Insurance America (Justin Loew v. Menard, Inc., and XL Insurance America) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Justin Loew v. Menard, Inc., and XL Insurance America, (iowa 2024).

Opinion

IN THE SUPREME COURT OF IOWA

No. 22–1894

Submitted November 16, 2023—Filed February 9, 2024

JUSTIN LOEW,

Appellant,

vs.

MENARD, INC. and XL INSURANCE AMERICA,

Appellees.

Appeal from the Iowa District Court for Polk County, Samantha

Gronewald, Judge.

A workers’ compensation claimant appeals the district court’s order

denying his petition for judicial review of agency decision denying his claim for

workers’ compensation benefits. DISTRICT COURT JUDGMENT REVERSED AND

REMANDED WITH INSTRUCTIONS. McDonald, J., delivered the opinion of the court, in which all participating

justices joined. May, J., took no part in the consideration or decision of the case. Paul Thune of Thune Law Firm, West Des Moines, for appellant.

Kent Smith and Rachael D. Neff (until withdrawal) of Smith Mills Law, P.C.,

Cedar Rapids, for appellees. 2

MCDONALD, Justice. Justin Loew suffered two lower back injuries in the course of his

employment with Menard, Inc. With respect to the first injury, Loew filed a

petition for workers’ compensation benefits, and the commissioner found the

injury caused 20% functional impairment to Loew’s lower back. Loew received

compensation for that injury based on a 30% reduction in his earning capacity.

With respect to the second, later injury, the commissioner found the injury

caused an 8% functional impairment to Loew’s lower back, increasing his

functional impairment from 20–28%. Based on statute, Loew was entitled to

compensation for this new injury based “upon [his] functional impairment

resulting from the injury, and not in relation to [his] earning capacity.” Iowa Code

§ 85.34(2)(v) (2018). The commissioner concluded, however, that Menard was

not required to pay compensation in this case. The commissioner reasoned

Menard was entitled to an offsetting credit because the 30% reduction in Loew’s

earning capacity was greater than the 28% functional impairment to Loew’s

back. The commissioner erred in crediting Menard in this case for its prior

payment. Compensation based on loss of earning capacity and compensation

based on functional impairment are incommensurables; offsetting one against the other is like determining “whether a particular line is longer than a particular

rock is heavy.” Bendix Autolite Corp. v. Midwesco Enters., Inc., 486 U.S. 888, 897

(1988) (Scalia, J., concurring in the judgment).

I.

Iowa’s workers’ compensation system dates to 1913. See 1913 Iowa Acts

ch. 147; Baker v. Bridgestone/Firestone, 872 N.W.2d 672, 676 (Iowa 2015). The

principles and purposes of the workers’ compensation system are well

understood. See Baker, 872 N.W.2d at 676. Generally, the workers’ compensation system rests on the policy judgment “that the disability of a 3

work[er] resulting from an injury arising out of and in the course of his [or her]

employment is a loss that should be borne by the industry itself . . . and not

suffered alone by the work[er] or the employer.” Id. (alterations and omission in

original) (quoting Tunnicliff v. Bettendorf, 214 N.W. 516, 517–18 (Iowa 1927)).

The system imposes a series of tradeoffs on employers and employees. “In the

grand bargain removing workers’ compensation matters from the civil justice

system, employers receive immunity from potentially large tort lawsuits . . . on

the condition that they pay compensation benefits for injuries arising out of and

in the course of employment without regard to fault.” Id. at 676–77. Under this

system, employers have an “obligation to pay compensation benefits in the

correct amount promptly when they are owed to injured employees.” Id. at 678.

To that end, it is “a rule of statutory interpretation deeply embedded throughout

our caselaw” that “[w]e liberally construe workers’ compensation statutes in

claimants’ favor to effectuate the statute’s humanitarian and beneficent

purpose.” Id.

Under Iowa law, “[e]very employer . . . shall provide, secure, and pay

compensation according to the [Code] for any and all personal injuries sustained

by an employee arising out of and in the course of the employment.” Iowa Code § 85.3(1). Compensation for an injury resulting in any permanent disability

“shall be payable to an employee” pursuant to Iowa Code section 85.34.

Compensation for an injury resulting in a permanent partial disability,

specifically, is governed by section 85.34(2). When an employee suffers a

permanent partial disability, the employee’s “compensation shall be based upon

the extent of the disability and upon the basis of eighty percent per week of the

employee’s average spendable weekly earnings.” Id. § 85.34(2). “For all cases of

permanent partial disability[,] compensation shall be paid” in one of two ways. Id. 4

First, in certain cases, compensation for permanent partial disability shall

be based on functional impairment to the injured body part and limited to the

percentage loss of the physiological capacity of the injured body part based on a

set number of weeks. See id. § 85.34(2)(a)–(v); Chavez v. MS Tech. LLC, 972

N.W.2d 662, 667 (Iowa 2022); Second Inj. Fund of Iowa v. Bergeson, 526 N.W.2d

543, 547 (Iowa 1995). In these cases, the “extent of loss or percentage of

permanent impairment shall be determined solely by utilizing the guides to the

evaluation of permanent impairment, published by the American medical

association, as adopted by the workers’ compensation commissioner.” Iowa Code

§ 85.34(2)(x). Iowa Code section 85.34(2)(a)–(u) lists different body parts and the

corresponding weeks of compensation that must be paid for an impairment to

the scheduled body part. To illustrate, section 85.34(2)(a) provides that for the

loss of a thumb, an employee is entitled to compensation for sixty weeks. Id.

§ 85.34(2)(a). If an employee suffered a work injury resulting in a 10% functional

impairment to the thumb, the employee would be entitled to six weeks’

compensation (10% of sixty weeks). Permanent partial disabilities compensated

pursuant to paragraphs (a)–(u) are referred to as scheduled injuries.

Second, in “all cases of permanent partial disability other than those . . . described or referred to in paragraphs ‘a’ through ‘u’ . . . , the compensation shall

be paid” based on “the number of weeks in relation to five hundred weeks as the

reduction in the employee’s earning capacity caused by the disability.” Id.

§ 85.34(2)(v). Determining an injured employee’s compensation based on the

employee’s reduction in earning capacity is known as the industrial method. See

Mortimer v. Fruehauf Corp., 502 N.W.2d 12, 14–15 (Iowa 1993) (stating the

industrial method measures “the loss to the employee’s earning capacity”).

Functional impairment to the body is only one of many factors considered in measuring an employee’s reduction in earning capacity. See Sherman v. Pella 5

Corp., 576 N.W.2d 312, 321 (Iowa 1998). “Measuring the employee’s loss of

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Related

Bendix Autolite Corp. v. Midwesco Enterprises, Inc.
486 U.S. 888 (Supreme Court, 1988)
Sherman v. Pella Corp.
576 N.W.2d 312 (Supreme Court of Iowa, 1998)
Second Injury Fund of Iowa v. Bergeson
526 N.W.2d 543 (Supreme Court of Iowa, 1995)
Doe v. Iowa Department of Human Services
786 N.W.2d 853 (Supreme Court of Iowa, 2010)
Mortimer v. Fruehauf Corp.
502 N.W.2d 12 (Supreme Court of Iowa, 1993)
Cowell v. All-American, Inc.
308 N.W.2d 92 (Supreme Court of Iowa, 1981)
Second Injury Fund of Iowa v. Shank
516 N.W.2d 808 (Supreme Court of Iowa, 1994)
Bruce Baker v. bridgestone/firestone and Old Republic Insurance
872 N.W.2d 672 (Supreme Court of Iowa, 2015)
Tunnicliff v. Bettendorf
214 N.W. 516 (Supreme Court of Iowa, 1927)
Nextera Energy Resources LLC v. Iowa Utilities Board
815 N.W.2d 30 (Supreme Court of Iowa, 2012)
Kelly Brewer-Strong v. HNI Corporation
913 N.W.2d 235 (Supreme Court of Iowa, 2018)
Whiddon v. Southern Concrete Pumping, LLC
114 So. 3d 18 (Court of Appeals of Mississippi, 2013)

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