Iowa Workers’ Compensation Refresher: Cardiovascular Injuries

The Iowa Supreme Court has adopted special rules regarding compensation for cardiovascular injuries. In order for an employer to be found liable for a cardiovascular injury, the employee must prove that employment was both the medical and legal cause of the injury. Riley v. Oscar Mayer Foods Corp., 532 N.W.2d 489 (Iowa Ct. App. 1995).

Legal Causation is established under any of the following elements:

1. When heavy exertions ordinarily required by the job are superimposed on a defective heart, thereby aggravating or accelerating the previous condition;
2. Unusually strenuous employment exertion is superimposed on a pre-existing diseased condition; or
3. Damage results from continued exertion required by employment after the onset of heart attack symptoms.

Medical Causation is established through expert medical testimony. The employee has the burden of proof to show by a preponderance of the evidence that the employment contributed, in some material and substantial degree, to cause the employee’s injury.

The Iowa Supreme Court has also recognized that continued exertions from work that aggravate a heart attack may be compensable. Sondag v. Ferris Hardware, 220 N.W.2d 903 (Iowa 1974). However, if there is some personal causal contribution, the exertion through the course of employment must be greater than the exertion from non-employment related activities. Id.

For more information about compensable cardiovascular injuries, please contact Paul Barta at pbarta@baylorevnen.com or any of the Baylor Evnen Iowa Workers’ Compensation Attorneys at (402)475-1075).