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Iowa Supreme Court Clarifies Rules for “Idiopathic” Falls and Workers’ Compensation


Workers’ compensation covers injuries that arise “out of and in the course of employment.” Let’s say you fall off a ladder while performing some maintenance work at your employer’s office. That would clearly be an injury arising out of and in the course of your employment, so your employer would owe you workers’ compensation benefits.

But what if you fall at work due to an epileptic seizure or some obscure or unknown cause that is not directly tied to your job? These are known as “idiopathic” injuries. And in many states, employees cannot collect workers’ compensation at all for such accidents.

Does the Hardness of a Restaurant Floor Pose an “Increased Risk” of Injury to Employees?

The Iowa Supreme Court, however, recently weighed in on the subject and reached a different conclusion. The petitioner in this case worked for the respondent’s fast food restaurant in Council Bluffs. One evening, about two hours into his shift, the petitioner “experienced a full-body seizure,” according to eyewitness accounts. The seizure caused the petitioner to fall, strike his head on the tile floor, and sustain a serious brain injury that required surgical intervention.

This was not the petitioner’s first seizure. He suffered them before and after the accident described above. Because these seizures were a “personal condition,” the deputy commissioner of the Iowa Workers’ Compensation Commission denied the petitioner’s request for workers’ compensation benefits. The deputy commissioner stated, point-blank, that idiopathic falls “are not compensable under Iowa law.” The commissioner, and later an Iowa district court, both affirmed the deputy commissioner’s position.

But the Supreme Court did not. The justices noted there was only one prior published case in Iowa regarding idiopathic falls and workers’ compensation, which the Supreme Court decided in 2000. In that case, the Court said there was an exception to the general rule that employees were not entitled to workers’ compensation for idiopathic falls. That exception is for situations where “a condition of his employment increased the risk of injury.”

In the present case, the Court said the deputy commissioner, the commissioner, and the district court all incorrectly asserted that “as a matter of law that idiopathic falls onto level floors are not compensable.” Yet this ignores the existence of the increased-risk exception. In fact, it was possible that the “condition of the floor” at the time of the petitioner’s accident might have created an increased risk of injury. But the “hardness” of the floor was a “factual matter, not a legal one,” for the workers’ compensation commissioner to consider.

Speak with an Iowa Workers’ Compensation Attorney Today

Workers’ compensation cases often turn on the specific facts surrounding an employee’s injury. That is why it is important to consult with a qualified Southeast Iowa workers’ compensation lawyer following an accident. An attorney can help make sure you have all of the facts before taking a claim to the Workers’ Compensation Commission. So if you need advice or assistance, contact the Noyes Law Office, P.C., at 641-472-3236 to schedule a free, no-obligation consultation today.


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