More Claims, Broader Coverage: How Two Iowa Cases Reshaped the Second Injury Fund
February 12, 2026
Two recent Iowa Supreme Court decisions have dramatically expanded who qualifies for Second Injury Fund benefits.
The Second Injury Fund (“SIF”) has been a staple of Iowa workers’ compensation law for decades. Developed in the wake of World War II, it incentivized employers to hire disabled employees by limiting the amount of liability they would incur in the event that employee became injured at work. If an employee has a pre-existing disability that affects a scheduled body part—which, in Iowa, includes arms, hands, legs, feet, and eyes—and then suffers a work injury that combines with the first disability to create a greater level of impairment, the employer is only liable for the compensation attributable to the work injury itself. The SIF pays the additional compensation resulting from the combined disabilities.
Historically, Iowa courts held that a workplace accident had to result in a scheduled injury before the SIF would pay any additional compensation for a combined disability. If a workplace accident resulted in an unscheduled injury—which, in Iowa, is defined as an injury to a body part or organ other than those explicitly listed as scheduled—the SIF was not liable for any additional payments. Two recent cases, however, have resulted in significant changes to this framework—and have drastically increased the amount of claims that are eligible for reimbursement from the SIF.
In Delaney v. Second Injury Fund of Iowa, decided by the Supreme Court of Iowa on 5/10/2024, the Court held that an employee who sustained an injury to her vascular system was nonetheless potentially eligible for benefits from the SIF. Delaney, 6 N.W.3d 714, 719 (Iowa 2024). Injuries to the vascular system are considered unscheduled by the Iowa Workers’ Compensation Commission; however, in this case, the injury to the vascular system was a lymphedema in the workers’ right leg. Id. at 718. Since the vascular system injury was localized to a scheduled body part, the Court held that it was sufficient to entitle the claimant to SIF benefits, specifically stating that “an injury to a bodily system may result only in localized loss to use of a scheduled member” and thus trigger eligibility for SIF benefits. Id. at 720. On 12/13/2024, the Court doubled down on this decision in Strable v. Second Injury Fund, specifically stating that the SIF’s liability depends on the specific parts of the body that are permanently injured in subsequent injuries—and not on “how they are compensated.” Strable, 14 N.W. 3d 742, 748.
As a result of this, the landscape of SIF liability looks very different in 2026. Now, any injury to an arm, hand, leg, eye, foot, or eye can trigger SIF liability if the injured employee has a qualifying pre-existing disability. Given the burden this could potentially impose upon the SIF, a state-run organization with limited funds, it is possible that future legislation could change this. For now, employees with pre-existing disabilities have more avenues to receive compensation for their injuries than ever before.
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Learn when employees can seek alternate care in Iowa workers’ compensation cases and what must be proven under Iowa Code section 85.27.
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Understand what functional capacity evaluations can and cannot prove in Iowa workers’ compensation cases and how they are weighed as evidence.
What Workers’ Compensation Is Designed to Do Workers’ compensation is a system created to provide benefits to employees who are injured while performing their job duties. In Iowa, this system is intended to offer medical care and wage replacement without requiring injured workers to prove fault. At the same time, workers’ compensation limits an employer’s exposure to lawsuits by providing an exclusive remedy in most workplace injury situations. This balance is a key feature of the system. Who Is Covered Under Iowa Workers’ Compensation Law Most employees in Iowa are covered by workers’ compensation, regardless of whether the injury occurred suddenly or developed over time. Coverage generally applies when an injury arises out of and in the course of employment. There are limited exceptions depending on the nature of the work and employment relationship. Understanding whether an injury qualifies often depends on specific facts and circumstances. Types of Benefits Available Workers’ compensation benefits in Iowa may include medical treatment related to the injury and partial wage replacement if the injury prevents an employee from working. In some cases, benefits may also address permanent impairment or long-term disability. The type and duration of benefits depend on the nature of the injury and how it affects an employee’s ability to work. Why Understanding the System Matters Many injured workers are unfamiliar with workers’ compensation until an injury occurs. Misunderstanding how the system works can lead to missed deadlines or confusion about available benefits. Learning the basics helps injured workers better navigate the process and set realistic expectations. Final Thoughts Workers’ compensation in Iowa is designed to provide support after a workplace injury, but the process can be complex. Understanding how the system works is an important first step for anyone dealing with a work-related injury. This content is for general informational purposes and does not constitute legal advice.
Learn how shoulder injuries are classified under Iowa workers’ compensation law and what that means for benefits, impairment, and claim outcomes.
Without strong objective evidence, it is very possible for claims to fail.
When testimony conflicts with the evidence, credibility becomes the deciding factor.
On August 27, 2025, the Iowa Workers’ Compensation Commission issued a decision in Irvin v. Tyson Fresh Meats. Deputy Amanda R. Rutherford ruled in favor of the defendant, who was represented by Jason Wiltfang of Corridorlaw Group Iowa, P.C. In her decision, Deputy Rutherford found that the evidence in the record was insufficient to establish that the claimant’s duties resulted in a cumulative injury. While explaining the rationale behind her decision, the Deputy paid particular attention to the vague job description that Irvin provided to her medical expert. In the letter sent to her expert requesting an opinion and providing background information, Irvin included an excerpt from her Answers to Defendant’s Interrogatories that stated that, at work, “she made 500 to 1,000 boxes daily, as well as stacked boxes, moved boxes, and put them on the line, down chutes or on top units” and that “the job required repetitive lifting, bending, and twisting.” Irvin , File No. 23009752.01 (Arb. 1/31/2025) at 15. However, Irvin did not “provide pertinent details such as weighs, sizes, amount of force needed, and/or explain body mechanics that could have caused her alleged injuries.” Id . Deputy Rutherford stated that, because of this omission, the claimant’s expert was “not given an accurate, detailed and/or complete job description before authorizing his report.” Id . The fact that the claimant’s expert based his examination on an incomplete job description ultimately proved fatal to Irvin’s case. As the Deputy noted in her decision, “[i]n a cumulative injury claim, a medically supported diagnosis, detailed and complete job description, and clearly articulated mechanism of injury are essential evidence.” Id. Without that evidence, it is very difficult for claimants to meet their burdens of proof. The decision in Irvin goes to show that, when it comes to cumulative injury cases, experts should be provided with complete job descriptions—otherwise, the flawed foundation of the expert’s opinion can render it unpersuasive.
On May 16, 2025, the Iowa Workers’ Compensation Commission issued a decision in Caballero v. Tyson Fresh Meats , File No 23005158.01 . Deputy Erin Q. Pals ruled in favor of the defendant, who was represented by Jason Wiltfang of Corridorlaw Group Iowa, P.C. In her decision, Deputy Pals found that the claimant failed to prove that he sustained an injury which arose out of and in the course of his employment. This finding was shaped in large part by the disparity between the parties’ IMEs. The claimant’s expert’s opinions made broad “blanket statements” regarding causation that cited neither the medical record nor the AMA Guides , the Deputy found. The defense’s expert, on the other hand, related all of his opinions to the medical record and cited the AMA Guides to the Evaluation of Disease and Injury Causation to further support his findings. The approach employed by the claimant’s expert, Farid Manshadi, MD, failed to persuade the Deputy that the claimant’s employment caused his injury. Deputy Pals noted the paucity of claimant’s argument on several occasions, observing that claimant’s expert provided no rationale for his opinions despite being the only physician to relate the claimant’s injuries to his activities at Tyson. When describing the importance of expert evidence to establishing causation, Deputy Pals noted that “[t]he weight to be given to an expert opinion is determined by the finder of fact and may be affected by the accuracy of the facts the expert relied upon as well as other surrounding circumstances.” Applying that standard to the facts of this case, Deputy Pals found “the blanket, cursory causation opinions of Dr. Manshadi” to be less persuasive than those of the defendant’s experts. This is a lesson that both claimants and defendants would do well to remember. The decision in Caballero is proof that an expert opinion, including the methodology applied and reasoning provided by the expert, has the potential to make or break a case.
Legal Update: Recent Iowa Supreme Court Ruling Alters Worker’s Compensation Landscape
