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Asmus vs Waterloo Community School District and Employers Mutual Companies, 722 N. W. 2d 653 (Iowa 2006)
Asmus, a middle school teacher for 26 years in the Waterloo Community School District alleged she is disabled from sever state of depression caused by the stresses that arose from an alleged tyrannical working environment at school. The worker’s compensation commissioner found that she established the medical causation elements of a work-engendered mental disability but had not proven the necessary elements to establish legal causation.
A purely mental injury may be conpensable under the workers’ compensation laws in the absence of an accompanying physical injury. In order to prevail on such a claim the injured worker must prove medical causation and legal causation. Medical causation simply requires a claimant to establish that the alleged mental condition was in fact caused by employment-related activities. Legal causation, on the other hand, presents a question a question of whether the policy of the law will extend responsibility to those consequences that have in fact been produced by the employment. The standard for legal causation is whether the claimant’s stress was of greater magnitude than the day to day mental stresses experience by other workers employed in the same or similar jobs, regardless of the employer. The supreme court concluded while evidence presented by the claimant would permit a finding of legal causation it does not compel such a finding as a matter of law. The ultimate decision in such cases is entrusted to the agency.
Claimant also challenged the legal requirements on a constitutional basis claimant they denied equal protection of the law because an additional burden is placed on mental injury claims that does not exist in establishing compensable physical injury. This assertion is premised on the fact that ordinarily it not required as a condition of compensability that workplace hazards must be of a specified magnitude in order to produce a compensable injury while such a requirement has been imposed with respect to mental injury claims. Since the law did not affect a fundamental right it only needed a rational basis to be upheld. The court held that the law has a rational basis because if all a claimant had to prove was causation in fact than this would convert the worker’s compensati0n system into general mental health insurance because few workers with nontraumatic mental problems could not show that job stress somehow contributed to that condition. The need to protect against that undesirable consequence provides a rational basis for the standard of legal causation that has been adopted.
Posted by Richard G. Book on April 30, 2007 7:50 PM
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