Iowa Workers’ Compensation cases can go through several levels of appeal.  The case is first tried to a Deputy Workers Compensation Commmissioner who issues a decision.  The case can next be appealed to the Iowa Workers Compensation Commissioner, then the Iowa District Court, then the Court of Appeals or Iowa Supreme Court.  The appellate process can take a several years to complete.

After a Deputy Commissioner listens to the evidence he/she writes an “Arbitration Decision.”  This is initial factual and legal conclusions in the case.  From here, the losing party can then appeal to the Workers Compensation Commissioner.  The Commissioner reviews the record “de novo.”  Meaning, the Commissioner can accept or reject the findings and conclusions reached by the Deputy Commissioner without giving any weight to the initial Deputy Commissioner’s findings.

After the Workers Compensation Commissioner reaches his appeal decision, the losing party can then appeal further to the Iowa District Court.  If the Workers Compensation Commissinoer reversed the initial Deputy Commissioner Decision, then the findings and conclusions of the initial Deputy Commissioner should carry no weight before the District Court on appeal.  In a recent Iowa Court of Appeals Case, O’Reilly Auto Parts vs. Alexander the Court of Appeals noted “the deputy commissioner’s proposed findings are not in consideration on judicial review.  Only final agency action is subject to judicial review.”

Accordingly, the Iowa District Court and subject Appellate Courts should only review the Findings made by the Commissioner, not findings made by the Deputy Commissioner.  The Courts reveiw the Iowa Workers Compensation Commissioner’s decisions under several various standards.

–Ryan Beattie