Iowa: Hardness of Floor Should Have Been Considered in Idiopathic Fall Case

A divided Supreme Court of Iowa recently held that all work-related risk factors must be considered in determining the compensability of an idiopathic fall—even the hardness of the floor. Accordingly, it was error for the Commissioner and a lower court to conclude, as a matter of law, that a claimant’s fall to a level floor could not be compensable. Quoting Larson’s Workers’ Compensation Law, the majority determined that the employee should have been allowed to show that conditions of the employment—here, a ceramic tile floor—increased the risk of injury.

Thomas A. Robinson, J.D., the Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is co-author of Larson’s Workers’ Compensation Law (LexisNexis).

LexisNexis Online Subscribers: Citations below link to Lexis Advance.

See Bluml v. Dee Jay’s Inc., 2018 Iowa Sup. LEXIS 101 (Nov. 16, 2018)

See generally Larson’s Workers’ Compensation Law, § 9.01.

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law

For a more detailed discussion of the case, See