Iowa Workers' Compensation Lawyer Blog
You can fall at work and be injured in an infinite number of ways. Fortunately, most falls do not result in a serious injury. However, in a small number of cases a fall at work can lead to substantial problems. The most common injuries from a fall at work are a knee injury, a wrist injury, a shoulder injury, a back injury, or a head injury.
The Iowa law about when a fall at work should be compensated under the workers’ compensation system is extensive and complicated. As a general matter a fall that is caused by something in the work environment is considered to be a work comp injury. Common examples of such a situation include:
1. Slipping and falling on some sort of liquid on the floor; and
2. Tripping over a tool or another part of the work surroundings.
If a person falls from a ladder, a roof, or some other sort of elevated position that is generally treated as a work comp injury.
If a person falls at work because of a personal health condition and is injured such a fall is usually not considered to be a workers’ compensation injury. Examples of such “personal health” falls would be if someone falls from epileptic seizure, if someone with diabetes faints and falls because of low blood sugar, or if a person with a neurological problem falls because of this condition.
There are two general exceptions that do allow a person who falls because of a “personal health” condition to receive work comp benefits. The first is when something at work triggered the personal health condition to flare up and cause the fall. For example, if flickering lighting at work triggered an epileptic seizure the resulting fall could be treated as a work injury. Second, if a person falls because of a personal health condition and the work environment aggravated the injury from the fall, then the person can be entitled to workers’ compensation benefits for the results of a fall. For example, if a person falls at work because of low blood sugar, but strikes her head on a sharp edge of machinery as they fall, the head injury can be treated as a work comp injury.
You are generally not entitled to workers’ compensation benefits if you have an unexplained fall at work when walking on flat ground.
Two fairly recent Iowa Appellate court cases analyze the workers’ compensation law concerning falls, and give some insights into how fall cases are decided.
Lakeside Casino v. Blue, 743 N.W.2d 169 (Iowa 2007) involved a worker who stumbled while coming down stairs at work. The Court found that the worker was not paying attention, and did not stumble because of any particular defect with the stairs, and the stairs posed no more danger than a typical set of stairs that could be found anywhere else. Nonetheless, the Court found that the stairs did create an actual risk of stumbling or falling, and this was sufficient to conclude that her resulting injuries arose out of her employment. Therefore, the injured worker was entitled to receive workers’ compensation benefits.
Ottumwa Regional Health Center v. Mitchell, 752 N.W.2d 35 (Iowa App. 2008) is a Court of Appeals Decision involving a hospital worker who was changing the linen and a mattress in a patient’s room. As the worker approached the bed, her right foot went out from under her and she fell. The worker testified that she did not see water or anything else on the floor, and that it just looked slick. The worker did not know what caused her to fall.
The Court of Appeals concluded that the details of the fall did not show an increased risk of danger to the worker, and therefore she was not entitled to recover workers’ compensation benefits.
The Iowa case law involving falls at work is a particularly complicated area of work comp law. Cases with very minor factual differences can have completely opposite results. If you are injured in a fall at work you should consult with an experienced Iowa workers’ compensation lawyer to determine whether you have a compensable claim.