Lorri Hagen v. Serta/National Bedding Co., LLC, and Safety National Casualty Co.

CourtSupreme Court of Iowa
DecidedJanuary 5, 2024
Docket22-0684
StatusPublished

This text of Lorri Hagen v. Serta/National Bedding Co., LLC, and Safety National Casualty Co. (Lorri Hagen v. Serta/National Bedding Co., LLC, and Safety National Casualty Co.) 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.

Bluebook
Lorri Hagen v. Serta/National Bedding Co., LLC, and Safety National Casualty Co., (iowa 2024).

Opinion

IN THE SUPREME COURT OF IOWA

No. 22–0684

Submitted November 16, 2023—Filed January 5, 2024

LORRI HAGEN,

Appellee,

vs.

SERTA/NATIONAL BEDDING CO., LLC, AND SAFETY NATIONAL CASUALTY CO.,

Appellants.

On review from the Iowa Court of Appeals.

Appeal from the Iowa District Court for Worth County, Christopher Foy,

Judge.

An employer and insurance carrier seek further review of the district

court’s ruling on a claimant’s petition for judicial review that reversed the work-

ers’ compensation commissioner’s exclusion of the claimant’s untimely evidence.

DECISION OF COURT OF APPEALS VACATED; DISTRICT COURT JUDGMENT REVERSED AND CASE REMANDED WITH INSTRUCTIONS. Christensen, C.J., delivered the opinion of the court, in which all justices

joined.

Lindsey E. Mills of Smith Mills Schrock Blades, P.C., West Des Moines, for

appellant.

John M. Loughlin of Loughlin Law Firm, Cherokee, for appellee. 2

CHRISTENSEN, Justice. A workers’ compensation claimant failed to timely certify her expert wit-

nesses in accordance with the deputy workers’ compensation commissioner’s

scheduling order and Iowa Administrative Code rule 876—4.19(3). The claimant

also failed to produce these experts’ reports at least thirty days before the arbi-

tration hearing, serving them instead around two weeks before the hearing com-

menced. Upon objection from the employer and its insurance carrier, the deputy

determined the receipt of the reports would be unfairly prejudicial and excluded

the reports under Iowa Administrative Code rule 876—4.19(3)(e). The commis-

sioner affirmed this decision, but the district court reversed on judicial review.

The court of appeals, over a dissent, affirmed the district court’s reversal,

and we granted further review. For the reasons explained below, we vacate the

court of appeals decision, reverse the district court judgment, and remand to the

district court for entry of an order affirming the commissioner’s decision. The

commissioner’s decision to exclude untimely evidence is entitled to deference

because Iowa law tasks the commissioner with adopting and enforcing the rules

and procedures necessary to implement Iowa’s workers’ compensation laws. This

includes the rules governing evidentiary deadlines in workers’ compensation pro-

ceedings. Given this deference, we cannot say the commissioner abused his dis- cretion by excluding the untimely evidence here.

I. Background Facts and Proceedings.

Lorri Hagen was injured in the course of her employment with Serta/Na-

tional Bedding Co., LLC, on February 21, 2017, when a cart weighing upwards

of 350 pounds rolled over her right foot. At Serta’s request, Hagen underwent an

independent medical examination (IME) on July 22, 2019, with Dr. Gorsche, who

opined that Hagen had reached maximum medical improvement for the work 3

injury. On August 5, Hagen filed an arbitration petition seeking workers’ com-

pensation benefits from Serta and its insurer, Safety National Casualty Co. (col-

lectively, “Serta”). On November 5, Hagen requested agreement from Serta to

provide an IME under Iowa Code section 85.39 (2019), which Serta agreed to on

November 7.

The workers’ compensation commissioner filed an order on December 31

that set Hagen’s arbitration hearing for September 25, 2020, where one of the

disputed issues would be whether Hagen was permanently and totally disabled.

The order also established deadlines for discovery and the exchange and filing of

witness and exhibit lists and proposed exhibits. These deadlines largely followed

the time limits under Iowa Administrative Code rule 876—4.19(3), which governs

“prehearing procedure, completion of discovery and case management in con-

tested cases.”

Under rule 876—4.19(3)(b), Hagen was required to “certify to all other par-

ties the expert’s name, subject matter of expertise, qualifications, and a sum-

mary of the expert’s opinions” if she intended to introduce evidence from an ex-

pert. Iowa Admin. Code r. 876—4.19(3)(b). The rule also gave Hagen 120 days to

certify before the hearing and Serta 90 days before the hearing and required that

Hagen certify any rebuttal experts 60 days before the hearing. See id. Rule 876—4.19(3)(c) further provides that “[a]ll discovery responses, depositions, and

reports from independent medical examinations shall be completed and served

on opposing counsel and pro se litigants at least 30 days before hearing.” Id.

r. 876—4.19(3)(c).

The scheduling order set a 30-day deadline for the parties to serve a wit-

ness and exhibit list in accordance with rule 876—4.19(3)(d), ordering all parties

to “serve a witness and exhibit list and exchange all intended exhibits that were

not previously required to be served.” See id. r. 876—4.19(3)(d). Finally, the order 4

mandated the parties file proposed exhibits “[a]t least 14 days prior to hearing”

and any written objections or motions to exclude evidence at least 7 days before

the hearing. See id.

In accordance with rule 876—4.19(3)(e), the order notified the parties of

the following consequence for violating these deadlines:

If evidence is offered at hearing that was not disclosed in the time and manner required by this order, other rulings made by a deputy workers’ compensation commissioner or agency rules, the evidence may be excluded if the objecting party shows that receipt of the evi- dence would be unfairly prejudicial.

(Emphasis added); see also Iowa Admin. Code r. 876—4.19(3)(e).

The IME that Hagen requested was scheduled to occur with Dr. Kuhnlein

on May 19, 2020, but Dr. Kuhnlein’s office had to reschedule the IME for June 23

due to illness. On August 19, Hagen provided Serta with updated discovery re-

sponses and listed Tom Karrow as a vocational expert. Serta provided Hagen

with its vocational report on August 27. On the same day, which was less than

thirty days prior to the arbitration hearing, Hagen’s counsel informed Serta “that

he ha[d] inquired into the status of the two reports [from Dr. Kuhnlein and Kar-

row] and that they can be expected soon.” Both Karrow and Dr. Kuhnlein com-

pleted their reports on September 10. Hagen provided Serta with Dr. Kuhnlein’s

report on September 10 and Karrow’s report on September 11.

Hagen filed her proposed hearing exhibits on September 11, listing

Dr. Kuhnlein’s IME report as “exhibit 10” and Karrow’s vocational report as “ex-

hibit 11.” Neither Dr. Kuhnlein nor Karrow were timely certified as experts, and

their reports were not timely provided to Serta at least thirty days before the

hearing. Serta filed a written objection to these two exhibits a week before the arbitration hearing, arguing, 5

The production of Dr. Kuh[n]lein’s report after the 30-day deadline is prejudicial to Defendants as they were not aware of Dr. Kuhnlein’s opinions regarding the extent of impairment and permanent work restrictions until 15 days prior to the Arbitration Hearing. In addi- tion, Mr. Karrow’s report concluding that the claimant is perma- nently and totally disabled was produced to Defendants 14 days prior to the Arbitration Hearing. Given the late production of the reports, Defendants are unable to respond or rebut Dr. Kuhnlein or Mr. Karrow.

Serta renewed this objection at the arbitration hearing on September 25,

to which Hagen proposed leaving the record open for Serta to obtain rebuttal

reports.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Marovec v. PMX INDUSTRIES
693 N.W.2d 779 (Supreme Court of Iowa, 2005)
Trade Professionals, Inc. v. Shriver
661 N.W.2d 119 (Supreme Court of Iowa, 2003)
IBP, Inc. v. Al-Gharib
604 N.W.2d 621 (Supreme Court of Iowa, 2000)
Schoenfeld v. FDL Foods, Inc.
560 N.W.2d 595 (Supreme Court of Iowa, 1997)
Stephenson v. Furnas Electric Co.
522 N.W.2d 828 (Supreme Court of Iowa, 1994)
Boehme v. Fareway Stores, Inc.
762 N.W.2d 142 (Supreme Court of Iowa, 2009)
Ward v. Iowa Department of Transportation
304 N.W.2d 236 (Supreme Court of Iowa, 1981)
Ellis v. Union Electric Co.
729 S.W.2d 71 (Missouri Court of Appeals, 1987)

Cite This Page — Counsel Stack

Bluebook (online)
Lorri Hagen v. Serta/National Bedding Co., LLC, and Safety National Casualty Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/lorri-hagen-v-sertanational-bedding-co-llc-and-safety-national-iowa-2024.