Riley v. Oscar Mayer Foods Corp.

532 N.W.2d 489, 1995 Iowa App. LEXIS 45, 1995 WL 346870
CourtCourt of Appeals of Iowa
DecidedMarch 30, 1995
Docket94-198
StatusPublished
Cited by5 cases

This text of 532 N.W.2d 489 (Riley v. Oscar Mayer Foods Corp.) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Riley v. Oscar Mayer Foods Corp., 532 N.W.2d 489, 1995 Iowa App. LEXIS 45, 1995 WL 346870 (iowactapp 1995).

Opinion

CADY, Judge.

This is an appeal from a decision by the district court reversing the industrial commissioner’s denial of workers’ compensation benefits. We find substantial evidence in the record to support the commissioner’s decision, and reverse the district court.

Larry Riley died of a heart attack on the evening of November 13, 1985. He was at home when stricken, and was pronounced dead at a hospital a short time later. Larry was employed as a maintenance department mechanic for an Oscar Mayer packing plant, and had worked until 6:12 on the morning of November 13. He left work early that morning after indicating he did not feel well.

Larry’s widow, Mabel, sought workers’ compensation death benefits. She claimed Larry’s employment aggravated or accelerated his underlying or pre-existing heart condition, and contributed to or hastened his death. After the industrial commissioner ruled that Mabel failed to establish a causal connection between Larry’s work activities and his death, Mabel sought judicial review with the district court.

The district court found substantial evidence in the record that Larry performed very heavy work during his last shift. It concluded that this work, when superimposed on his pre-existing heart condition, caused his heart attack and subsequent death. The trial court reversed the decision of the Industrial Commissioner and remanded the case for a determination of benefits.

Oscar Mayer appealed. It claims substantial evidence supported the findings made by the commissioner that Mabel failed to prove the heart attack was work-related, and the district court erred by substituting its findings for those of the commissioner.

I. Scope of Review

Judicial review of worker compensation cases is at law, not de novo. Mortimer v. Fruehauf Corp., 502 N.W.2d 12, 13 (Iowa 1993). This reviewing standard applies to both the initial review in the district court, as well as the subsequent review by the appellate courts. Id. It limits judicial interference with a decision of the Industrial Commissioner to the correction of errors at law. See Dowell v. Wagler, 509 N.W.2d 134, 136 (Iowa App.1993).

The standard of review prescribed for worker compensation cases recognizes that it is the role of the Industrial Commissioner, not the court, to weigh the evidence. Holmes v. Bruce Motor Freight Inc., 215 N.W.2d 296, 298 (Iowa 1974). Courts are required to give deference to the fact finding role of the agency and must broadly and liberally construe its finding of fact to uphold, not defeat, the decision. Id. It is the same respect accorded a jury verdict. Paveglio v. Firestone Tire & Rubber Co., 167 N.W.2d 636, 640 (Iowa 1969).

Review at law means courts are bound by the findings of fact if supported by substantial evidence in the record as a whole. See Suluki v. Employment Appeal Bd., 503 N.W.2d 402, 404 (Iowa 1993). Evidence is substantial if reasonable minds would find it adequate to reach a given conclusion. Kostelac v. Feldman’s Inc., 497 N.W.2d 853, 856 (Iowa 1993). Substantial evidence is not absent simply because it is possible to draw different conclusions from the same evidence. Id. The focus of the judicial inquiry is whether the evidence is sufficient to support the decision made, not whether it is sufficient to support the decision not made. Coghlan v. Quinn Wire & Iron Works, 164 N.W.2d 848, 852 (Iowa 1969). A reviewing court may interfere with the agency’s findings only if the evidence is uncontradicted and reasonable minds could not draw different inferences. Longford v. Kellar Excavating & Grading, Inc., 191 N.W.2d 667, 668 (Iowa 1971). Legal error is present under the substantial evidence analysis when an agency reaches a conclusion based on uncontrovert-ed evidence which is contrary to the conclusion reasonable minds would reach. If evi *492 dence is in conflict, however, the reviewing court has no room to interfere. Kostelac, 497 N.W.2d at 856.

II. Recovery for Heart Attack

Our law allows an employee with a pre-existing heart condition or defect to recover workers compensation for a work related heart attack upon a showing of legal and medical causation. Briar Cliff College v. Campolo, 360 N.W.2d 91, 94-95 (Iowa 1984); Sondag v. Ferris Hardware, 220 N.W.2d 903, 905-06 (Iowa 1974). The legal test circumscribes the kind of work or exertion which must be present before the injury will be considered to have arisen out of the employment. Arthur Larson, Workmen’s Compensation Law § 38.83(a) (6th ed. 1994). It supplies the necessary causation between the work performed and the injury. The medical test requires medical evidence that the exertion or work in fact caused the heart attack. Id.

In Iowa, the legal causation component of the analysis has been satisfied under one of the three circumstances. The first situation is when heavy exertions ordinarily required by work are superimposed on a defective heart, aggravating or accelerating the pre-existing condition. Sondag, 220 N.W.2d at 905. The second situation involves an instance of unusually strenuous employment exertion, imposed upon a preexisting diseased condition. Id. The final situation supporting compensation is when the damage resulted from continued exertions required by the employment after the onset of the heart attack. Id. at 906. See Varied Enterprises, Inc. v. Sumner, 353 N.W.2d 407, 409 (Iowa 1984).

Under the first situation, the contribution of the employment to the risk of heart attack must take the form of an exertion greater than that of nonemployment life. Sondag, 220 N.W.2d at 905 (citing Arthur Larson, Workmen’s Compensation § 38.83). The comparison is not with the particular employee’s usual exertion in his or her employment but with exertions of normal non-employment life of the particular employee or any other person. Id. In the second situation, the comparison is between the employee’s normal work exertion and the work performed just prior to the onset of symptoms. See Guyon v. Swift & Co., 229 Iowa 625, 633-34, 295 N.W. 185, 189 (Iowa 1940).

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532 N.W.2d 489, 1995 Iowa App. LEXIS 45, 1995 WL 346870, Counsel Stack Legal Research, https://law.counselstack.com/opinion/riley-v-oscar-mayer-foods-corp-iowactapp-1995.