Understanding Workers’ Compensation in Iowa

Shoulder injuries, and how they are compensated, have been a controversial issue in Iowa law since 2017. Before the 2017 changes to Chapter 85 of the Iowa Code, shoulder injuries were considered injuries to the body-as-a-whole, and compensable for up to 500 weeks under the industrial disability analysis. After the changes, however, shoulders were treated as scheduled injuries that were compensable for only 400 weeks. On its surface, this sounds like a straightforward change. The years since, however, have seen considerable debate regarding what the term “shoulder” even refers to and exactly how an injury to the region should be assessed and compensated. Nowhere in the statute was the word “shoulder” defined. “Shoulder” was not defined in the AMA Guides , either, or used by doctors when assigning impairment ratings to the region. The term they used was “upper extremity,” which encompasses the entirety of the arm. Moreover, while authorities like Stedmans Medical Dictionary defined the shoulder joint narrowly as “a ball-and-socket synovial joint between the head of the humerus and the glenoid cavity of the scapula,” prior court rulings had decreed that the definition of shoulder also included the “tendons, ligaments, muscles, and articular surfaces connected to the glenohumeral joint.” Chavez v. MS Technology LLC , 972 N.W.2d 662, 667 (Iowa 2022). The end result of this was an ambiguity about what an injury to the shoulder entailed—an ambiguity that claimant-side attorneys used to argue that injuries to the shoulder should be defined as injuries to the joint alone. In their decision in Chavez v. MS Technology LLC , the Supreme Court of Iowa resolved this ambiguity by deciding that the word “shoulder,” as used in Section 85.34(2)(n) “must be defined in the functional sense to include the glenohumeral joint as well as all of the muscles, tendons, and ligaments that are essential for the shoulder to function.” Id. at 668. This decision did a lot to clarify how cases involving shoulder claims would proceed in Iowa; however, some questions still remain. Recently, plaintiff-side attorneys have begun arguing that upper extremity impairment ratings assigned to claimants with shoulder injuries should be multiplied by sixty percent in order to arrive at an impairment rating that applies exclusively to claimant’s shoulder. The rationale behind this theory is that it accounts for the shoulder joint’s involvement in the function of the upper extremity—which, according to the AMA Guides , is sixty percent. Whether or not this theory will prove successful in court remains to be seen. However, it has two significant hurdles to clear before it can become the law of the land: the fact that its rationale runs contrary to the Guides’ own directives for the issuance of impairment ratings, and the fact that this “weighting” has already been accounted for by the shoulder being worth 60% more than the upper extremity, as originally proposed in the 2017 amendments to the Iowa Workers’ Compensation Act. Claims involving shoulder injuries are likely to remain sources of controversy, debate, and novel theories for years to come. Defendants should be careful to ensure that injuries to the shoulder are treated solely as scheduled injuries in accordance with 85.34(2)(n). Claimants, on the other hand, should be mindful to take advantage of any opportunities to expand shoulder claims into body-as-a-whole claims—all while remembering that injuries to the muscles, tendons, and ligaments attached to the glenohumeral joint will not be sufficient for this purpose.

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

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