IOWA COURT OF APPEALS AFFIRMS SURVIVOR BENEFITS, RULING OVERDOSE WAS ACCIDENTAL, NOT INTENTIONAL

The Iowa Court of Appeals recently upheld an Agency decision to award survivor benefits to the widower of a claimant who died from a prescription drug overdose. The employer had appealed, arguing that the overdose was a suicide, which would bar survivor benefits under Iowa’s willful-injury defense (Iowa Code § 85.16(1))—a provision that excludes compensation for injuries resulting from the employee’s intentional self-harm.

Background

The claimant suffered an ankle injury in 2012, which the Commissioner held was the cause of chronic lower back pain and depression. In 2013, she was diagnosed with major depressive disorder.

In September 2016, the claimant died from an overdose of prescription medications which were prescribed to treat the compensable work-related injuries. The Commission ruled that the overdose was accidental and awarded survivor benefits to her husband. The employer contested the ruling, asserting that the death was a suicide and should be excluded from benefits under the willful-injury defense. The Iowa Court of Appeals, after reviewing the evidence, upheld the Commissioner’s decision, finding that substantial evidence supported the conclusion that the death was accidental.

Evidence Supporting Suicide

The employer argued that the claimant’s death was intentional, pointing to several key pieces of evidence:

1. Autopsy Report: The autopsy did not rule out the possibility of suicide, leaving the cause of death as “undetermined.”
2. Mental Health History: The claimant had been assessed by her counselors as a moderate suicide risk, and she had a history of suicide attempts.
3. Emotional Strain: The claimant had recently gone through some personal issues, which could have contributed to emotional distress.
4. Suicide Note: A note, which appeared to express suicidal thoughts, was found under a stack of papers on the claimant’s bed. However, the note was undated, unfinished, and its meaning unclear.

The employer argued that this evidence was substantial enough to prove the claimant's death was a suicide and, thus, survivor benefits should be denied to the claimant’s surviving husband.

Evidence Supporting Accidental Overdose

The Court of Appeals also considered evidence that suggested the claimant’s death was accidental:

1. Undetermined Cause of Death: Both the autopsy and death certificate listed the cause of death as “undetermined.” No expert opined that the death was a suicide.
2. History of Drug Misuse: The claimant had a history of taking medication in excess in order to become intoxicated rather than with the intent to harm herself.
3. Recent Behavior and Plans: The claimant had made plans to visit with others for the evening, suggesting she was not preparing for a suicide.
4. Family Testimony: The claimant’s son, who lived with her, reported that she appeared emotionally stable in the days leading up to her death. He speculated that she accidentally overdosed by taking extra medication, not realizing she had already taken a dose earlier.
5. Suicide Note: While the note found in the claimant’s home could be interpreted as a suicide note, it was undated, unfinished, and buried under a stack of papers. The Commissioner concluded that this note only suggested that the claimant had merely considered suicide in the days, months, or even years leading up to her death.

Court of Appeals Decision

The Court emphasized that the substantial-evidence standard does not demand that only one conclusion is possible, but rather that the evidence, when considered in its entirety, supports the decision. The Court also deferred to the Commission, which was responsible for assessing witness credibility and weighing conflicting evidence. The Court of Appeals noted that while the employer had presented facts that could suggest suicide, these facts were not conclusive. There was also substantial evidence supporting the finding that the claimant’s death resulted from an accidental overdose and, therefore, the decision of the Commission would not be overruled.

If you have questions about survivor benefits or any other questions regarding Iowa Workers’ Compensation, please reach out to Paul Barta or Adam Barrett at (402) 475-1075.