Toby Brown v. Quik Trip Corporation and CNA Insurance

Summary

The Iowa Supreme Court addressed whether an employee's post-traumatic stress disorder constituted a compensable mental/mental workers' compensation injury. The court held that legal causation may be established without evidence of stress experienced by similarly situated employees when the injury results from a readily identifiable, sudden, traumatic, and unexpected event. The court reversed the district court and remanded to the workers' compensation commissioner to determine the extent of the claimant's disability.

Holdings

1. When a mental-injury claim is based on a manifest event or events of a sudden traumatic nature arising from an unexpected cause or unusual strain, legal causation is established without proof of the stress experienced by similarly situated employees.
2. Brown established legal causation because the shooting-related incident and robbery were sudden, traumatic, and unexpected events occurring in the course of his employment.

Questions Presented

1. Whether a worker seeking benefits for a purely mental injury must present evidence concerning the stress experienced by similarly situated employees when the claim arises from sudden, traumatic, and unexpected workplace events.
2. Whether Brown established legal causation for his mental/mental workers' compensation claim.
3. Whether the case should be remanded to determine the extent of Brown's disability.

Disposition

reversed_and_remanded