Summary
The Iowa Supreme Court held that Sarah Kingsbury’s compromise settlement with Walmart barred her from pursuing benefits against the Second Injury Fund because the settlement did not establish Walmart’s liability or a degree of permanent disability. The court interpreted Iowa Code sections 85.35(10) and 85.64 and concluded that fixed employer liability is necessary before Second Injury Fund liability can be determined. The court reversed the district court and remanded with instructions to affirm the workers’ compensation commissioner’s dismissal of Kingsbury’s claim; Justice Waterman dissented, joined by Justice McDermott.
Court
Supreme Court of Iowa
Jurisdiction
Iowa Supreme Court
Decision date
April 24, 2026
Docket number
25-0717
Disposition
reversed_and_remanded
Questions Presented
- Whether a workers’ compensation claimant may continue pursuing Second Injury Fund benefits after entering a full and final compromise settlement with the employer that does not establish the employer’s liability for permanent disability.
- Whether Iowa Code sections 85.35(10) and 85.64(1) bar Kingsbury’s claim against the Second Injury Fund because the settlement left unresolved the existence and extent of permanent disability and did not establish a payment obligation by Walmart.
Holdings
- A claimant may not continue pursuing a Second Injury Fund claim after entering a full and final compromise settlement with the employer that does not establish the employer’s liability for a specified degree of permanent disability. The settlement is a final bar to further rights under the Iowa Workers’ Compensation Act regarding the subject matter of the compromise.
- A claimant and employer may structure a settlement that establishes the employer’s liability for part of the claim or identifies the extent of permanent disability, thereby permitting a subsequent claim against the Second Injury Fund.
Court Document
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