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Does Iowa Workers’ Compensation Cover Out-of-State Injuries?


You probably know that if you work for an employer in the State of Iowa and are injured on the job, you are entitled to receive workers’ compensation benefits. But what if the actual work-related injury occurs outside of the state? Can the employer get out of paying you based solely on where you were injured? Iowa law offers some of the best benefits to injured workers in the entire country, so whenever possible, insurers will go to great lengths to argue that Iowa lacks jurisdiction.

Court of Appeals: Contract Is Formed Where Employee Accepts Employer’s Offer

A recent Iowa Court of Appeals decision, Niday v. Roehl Transport, Inc., helps explain how the law treats such out-of-state injuries. This plaintiff in this case is a man who decided to make a mid-career switch to become a commercial truck driver. While attending classes at a local community college to earn his trucking license, the plaintiff noticed an advertisement posted by the defendant, a national trucking company based in Wisconsin. Although the defendant operates in Iowa, it did not have a physical terminal in the state.

The defendant subsequently hired the plaintiff and assigned him mostly to routes outside of Iowa. One day, after picking up a shipment of goods in Kentucky, the plaintiff suffered a heart attack. He subsequently filed for workers’ compensation benefits under Iowa law. The defendant maintained the Iowa Workers’ Compensation “lacked jurisdiction because the injury occurred outside of Iowa” and there were no other legal grounds that covered the plaintiff’s injury.

The Commission ultimately agreed with the defendant. But the Court of Appeals reversed. It agreed with the plaintiff that Iowa workers’ compensation law did apply here because the plaintiff was “working under a contract of hire made in this state and the employee regularly works in this state.” If both of these conditions are met, Iowa law applies regardless of where the employee’s injury occurred or whether the employer had a physical location in the state.

The defendant conceded the plaintiff “regularly worked in Iowa,” meeting the second condition. But the two sides disagreed as to the first condition–i.e., whether the plaintiff’s actual employment contract was “made” in Iowa. According to the plaintiff, the contract was made when he answered a telephone call (at his Iowa home) from a recruiter working for the defendant. During this call, the parties discussed the substantive terms of employment. The recruiter later mailed a letter to the defendant affirming the terms that were previously agreed to orally.

The defendant argued this was nothing more than a “conditional” employment offer, which did not become final until the plaintiff completed a number of training and testing requirements–which took place outside of Iowa. The Court of Appeals did not buy this argument, however, explaining that this “blurs the line between the formation of a contract and the fulfillment of conditions within an existing contract.” For purposes of workers’ compensation law, what matters is where “the last act necessary to a meeting of the minds”–an offer and acceptance–occurred. Here, the “last act” was the phone call. Consequently, the contract was formed in Iowa and the state’s workers’ compensation law applies.

Contact an Iowa Workers’ Compensation Lawyer Today

Even in cases where there is no dispute a work-related injury occurred in Iowa, employers may still try to avoid their legal responsibility to pay benefits. If you find yourself in such a position and need assistance from an experienced Southeast Iowa workers’ compensation attorney, contact the Noyes Law Office, P.C., today.


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