Perkins v. HEA of Iowa, Inc.

Summary

The Supreme Court of Iowa held that an employee's hepatitis C infection resulting from a specific workplace blood-exposure incident was an industrial injury under Iowa Code chapter 85, rather than an occupational disease under chapter 85A. The court further held that the workers' compensation limitations period began when the hepatitis C was diagnosed, not when the employee was merely exposed to the disease. The court affirmed the court of appeals and district court judgment reinstating the arbitrator's award.

Holdings

1. The infection was an 'injury' under chapter 85 because it originated from a sudden, specific traumatic event (a rupture of the patient's shunt causing blood exposure), not through passive exposure characteristic of an occupational disease.
2. The date of injury was the date Perkins discovered she had hepatitis C (April 20, 1996), not the date of exposure. Mere exposure to a disease does not trigger inquiry notice because the claimant has not yet suffered an injury.

Questions Presented

1. Whether Perkins's hepatitis C infection was an 'injury' under Iowa Code chapter 85 rather than an 'occupational disease' under chapter 85A.
2. Whether the two-year statute of limitations in Iowa Code section 85.26(1) began to run from the date of exposure or from the date of diagnosis under the discovery rule.

Disposition

affirmed