from the Iowa District Court for Polk County, Lawrence P.
seeks appellate review of an order affirming final agency
R. Rush and Christoph P. Rupprecht of Rush & Nicholson,
PLC, Cedar Rapids, for appellant.
M. Smith of Scheldrup Blades Schrock Smith, PC, West Des
Moines, for appellees Quaker Oats Company and Indemnity
Insurance Company of North America.
J. Miller, Attorney General, and Amanda R. Rutherford,
Assistant Attorney General, for appellee Second Injury Fund
Considered by Potterfield, P.J., and Bower and McDonald, JJ.
Keeran challenges the workers' compensation
commissioner's denial of her claim for workers'
compensation benefits. The agency record shows Keeran sought
workers' compensation benefits for cumulative injuries to
her knees allegedly sustained during the course of her
employment with Quaker Oats. The deputy commissioner found
Keeran failed to prove her knee injuries arose out of and in
the course of her employment with Quaker Oats and denied her
claim for benefits. Because the deputy commissioner found
Keeran failed to meet her burden of proof on the issues of
causation and compensability, the deputy commissioner
concluded the remaining issues presented were moot. Keeran
sought intra-agency review of the deputy's decision. The
commissioner affirmed the deputy's decision in its
entirety and adopted as final the relevant portions of the
deputy's decision. The district court affirmed the
commissioner's denial of Keeran's claim. Keeran
timely filed this appeal.
review is governed by the Iowa Administrative Procedure Act,
Iowa Code chapter 17A. See Lakeside Casino v. Blue,
743 N.W.2d 169, 172 (Iowa 2007). The standard of review
differs depending on the error alleged. See Jacobson
Transp. Co. v. Harris, 778 N.W.2d 192, 196 (Iowa 2010).
Factual challenges are reviewed for substantial evidence.
See id. "Evidence is substantial if a
reasonable mind would find it adequate to reach a
conclusion." Quaker Oats Co. v. Ciha, 552
N.W.2d 143, 150 (Iowa 1996). "If the error is one of
interpretation of law, we will determine whether the
commissioner's interpretation is erroneous and substitute
our judgment for that of the commissioner." Jacobson
Transp. Co., 778 N.W.2d at 196.
first claim of error, Keeran contends the agency applied the
wrong legal standard to determine whether Keeran's injury
and disability arose out of her employment with Quaker Oats.
"When the agency exercises its discretion based on an
erroneous interpretation of the law, we are not bound by
those 'legal conclusions but may correct misapplications
of the law.'" Meyer v. IBP, Inc., 710
N.W.2d 213, 219 (Iowa 2006) (quoting Stroup v. Reno,
530 N.W.2d 441, 443 (Iowa 1995)).
workers' compensation statute provides coverage for
'all personal injuries sustained by an employee arising
out of and in the course of the employment.'"
Id. at 220 (Iowa 2006) (quoting Iowa Code §
85.3(1) (2001)). "This statutory coverage formula gives
rise to four basic requirements: (1) the claimant suffered a
personal injury, (2) the claimant and the respondent had an
employer-employee relationship, (3) the injury arose out of
the employment, and (4) the injury arose in the course of the
employment." Id. "The failure of any one
requirement results in a denial of a claim for
benefits." Id. To prove an injury arose out of
employment, the claimant must establish a "causal
connection exists between the employment and the
injury." Id. at 222. In addition to showing a
causal connection between her employment and the injury, the
claimant must prove her work-related injury is the proximate
cause of her disability. See Ayers v. D & N Fence
Co., 731 N.W.2d 11, 17 (Iowa 2007). "In order for a
cause to be proximate, it must be a substantial factor."
Id. (citation omitted). If the alleged injury
resulted from the worsening, aggravation, or acceleration of
a preexisting condition or injury, a claimant may recover so
long as she can show a causal connection between the working
conditions and her injury. See Musselman v. Cent. Tel.
Co., 154 N.W.2d 128, 132 (Iowa 1967). "In other
words, the injury must not have coincidentally occurred while
at work, but must in some way be caused by or related to the
working environment or the conditions of [her]
employment." Miedema v. Dial Corp., 551 N.W.2d
309, 311 (Iowa 1996).
conclude the agency applied the correct legal standard to the
question of causation. Here, the agency stated Keeran needed
only to "show that those natural degenerative processes
were accelerated, speeded up or aggravated by her work
activities." This is a correct statement of the law.
See Musselman, 154 N.W.2d at 132. In addition, the
agency also stated Keeran was required to establish any
injury was a proximate cause of her resulting disability.
See Ayers, 731 N.W.2d at 17. ...