Summary
The Iowa Supreme Court reviews a workers’ compensation dispute arising from Kevin Koeller’s left shoulder injury while employed by Cardinal Logistics Management Corporation. The court holds that the workers’ compensation commissioner correctly relied on expert medical evidence regarding causation but incorrectly applied a 25% multiplier under the AMA Guides to the impairment rating for Koeller’s distal clavicle excision. The court vacates in part the court of appeals’ decision, reverses in part the district court’s judgment, and remands for further proceedings.
Topics
Practice areas
Questions Presented
- Whether the workers' compensation commissioner could accept an expert's factual and medical opinions while independently interpreting the AMA Guides adopted by Iowa law.
- Whether the AMA Guides require the 25% Table 16-18 multiplier to be applied to the 10% upper-extremity impairment listed for a distal clavicle excision in Table 16-27.
- Whether substantial evidence supported the commissioner's determination that Koeller's distal clavicle excision resulted from the workplace injury.
Holdings
- Iowa Code section 85.34(2)(x) permits the workers' compensation commissioner and reviewing courts to review and interpret the AMA Guides rather than treating an expert's legal interpretation as controlling.
- The 10% upper-extremity impairment value in AMA Guides Table 16-27 for a distal clavicle excision is not subject to the 25% Table 16-18 multiplier.
- Substantial evidence supported the commissioner's acceptance of Dr. Taylor's opinion that Koeller's distal clavicle excision resulted from the workplace injury.
Key quotations
“Also, and this is important for the present case, we do not read section 85.34(2)(x) as prohibiting the commissioner—or courts—from reviewing expert interpretations of the AMA Guides.” (at 10-11)
“The specifics in section 16.7b of the AMA Guides prevail over the general statement in section 16.7.” (at 15)
“The AMA Guides provide that the values in Table 16-27 for upper extremity impairment are not subject to such a multiplier.” (at 15)
Factual background
Koeller, a semitruck driver for Cardinal Logistics Management Corporation, injured his left shoulder on October 5, 2022, while trying to open a jammed truck door. He underwent surgery that included a distal clavicle excision and continued to experience numbness and tingling afterward. Dr. Bollier assigned a 6% impairment rating and attributed the clavicle procedure to a non-work-related condition, while Dr. Taylor assigned a 19% rating, including a 10% rating for the distal clavicle excision; the commissioner credited Dr. Taylor's medical causation opinions but applied a 25% multiplier from AMA Guides Table 16-18, reducing the overall rating to 13%.
Procedural history
After a workers' compensation deputy commissioner determined Koeller's permanent partial impairment and resolved other benefit issues, the commissioner affirmed with a minor modification. Koeller and Cardinal each sought judicial review in district court, which dismissed both petitions and affirmed the commissioner's decision. The Iowa Court of Appeals affirmed, and the Iowa Supreme Court granted Koeller's application for further review, affirming the court of appeals on alternate medical care but reviewing the permanent-partial-disability issue.
Remand instructions
The case was remanded to the Iowa District Court for Polk County so that the district court could remand it to the workers' compensation commissioner for further proceedings consistent with the opinion, including application of the AMA Guides without the Table 16-18 multiplier to the distal clavicle excision.