Iowa Supreme Court Revises Interpretation of Vascular Injury Compensation

In a recent ruling, the Iowa Supreme Court has corrected a 44-year-old misinterpretation of workers’ compensation law regarding vascular injuries. The case, Delaney v. Second Injury Fund of Iowa, involved a worker who suffered injuries to both legs over her career, the latter leading to lymphedema—a condition previously considered a per se injury to the body as a whole. This classification significantly impacted the benefits she was entitled to from Iowa’s Second Injury Fund.

The court found that previous rulings had incorrectly interpreted vascular injuries as inherently unscheduled injuries affecting the body as a whole. This misinterpretation stemmed from the 1980 Blacksmith v. All-American, Inc. decision, which did not explicitly classify such injuries as unscheduled. The Supreme Court’s clarification emphasizes that injuries to the vascular system should not automatically be treated as affecting the entire body, thus impacting how benefits are calculated and awarded.

This decision marks a pivotal shift in how workers’ compensation cases will be handled in Iowa, particularly affecting how injuries are classified and the subsequent liabilities of the Second Injury Fund. The court has remanded the case for a reassessment of the worker’s benefits, focusing on the actual impact of the injuries on her earning capacity rather than the type of injury sustained. This change aims to prevent potential double recovery and ensure fair compensation based on actual impairments.