Note: There has been an update to this post due to legislation passed during the 2019 Iowa Legislative session. Joni provides information on the changes in Legislative Update: Idiopathic and Unexplained Falls.

The Iowa Supreme Court recently issued a decision that re-examined compensability of idiopathic injuries, specifically falls on level, unobstructed, and dry floors. In Bluml v. Dee Jay’s Inc., File No. 18-0317 (Iowa 2018), the claimant was working as a fast food employee at the time of the injury. He was handing a customer an order when he had a seizure and fell backwards onto a ceramic tile floor. He sustained a traumatic brain injury.

Workers’ Compensation Commission, District Court, and Iowa Court of Appeals Rulings

Deputy Workers’ Compensation Commissioner James Christenson denied benefits as a matter of law; idiopathic falls on level, unobstructed, and dry floors are not compensable. The claimant did not hit any tables, chairs, or kitchen equipment as he fell to the floor. The fall was on a level surface and the claimant did not fall from a height. Commissioner Joseph Cortese affirmed on appeal. However, Commissioner Cortese also found the injuries were worsened due to falling on a ceramic tile floor. The district court affirmed on judicial review and so too did the Iowa Court of Appeals.

Iowa Supreme Court Decision

The Iowa Supreme Court remanded the case finding that it should have been analyzed on the facts of the particular case, not as a matter of law. The court reasoned that if the work environment places a worker in a position that increases the effects of a fall, then it is compensable. Whether the condition of the floor posed an increased risk of injury should be determined factually just like any other workplace condition. The court noted that prior case law “did not foreclose the possibility that an especially hard floor could amount to such a hazard.”

Going Forward

The impact of this decision is that there is no set rule on whether idiopathic falls on level, unobstructed, and dry floors are compensable. Claimants have the opportunity to meet the increased-risk test when sustaining idiopathic falls on level, unobstructed, and dry floors by showing the hardness of the floor increased the risk of injury.