Archer Daniels Midland
v.
Donald Tuttle
Appellant
Archer Daniels Midland
Appellee
Donald Tuttle
Attorney for the Appellant
Peter J. Thill and Brandon W. Lobberecht
Attorney for the Appellee
Dennis Currell
Court of Appeals
Court of Appeals Opinion
Opinion Number:
Date Published:
Summary
Appeal from the Iowa District Court for Polk County, Christopher Kemp, Judge. REVERSED ON APPEAL AND CROSS-APPEAL. Heard at oral argument by Tabor, C.J., Langholz, J., and Doyle, S.J. Opinion by Tabor, C.J. (19 pages)
Donald Tuttle sustained two work-related injuries during his employment at Archer Daniels Midland (ADM): a left knee injury and a head injury. The deputy workers’ compensation commissioner granted Tuttle’s requests for alternate medical care for both claims. On judicial review, the district court affirmed the deputy’s grant of alternate medical care for Tuttle’s head injury but remanded the claim involving care for his knee to the deputy for a more specific finding. ADM appeals that judicial review order, advancing three arguments concerning care for Tuttle’s head injury: (1) the court erred in finding ADM unreasonably delayed treatment; (2) the court exceeded its jurisdiction and authority by making new factual findings not considered or relied upon by the deputy; and (3) even if the alleged treatment delay is actionable, the court erred in finding it was unreasonable under Iowa Code section 85.27(4) (2023). As for the knee injury, ADM argues the court erred in ordering a remand because there was insufficient evidence to conclude its authorized treatment was unreasonable. Tuttle cross-appeals, contending the remand was unnecessary because the agency applied the correct standard in making its factual findings. OPINION HOLDS: We reverse the district court’s order affirming the head-injury portion of the deputy’s alternate care decision. We also reverse the court’s remand and affirm the deputy’s decision granting alternate care for Tuttle’s knee injury.
