American Home Assurance
v.
Liberty Mutual Fire Insurance Company
American Home Assurance seeks further review after the court of appeals reversed the district court’s ruling on judicial review. The district court reversed the workers’ compensation commissioner’s decision and concluded American Home was entitled to reimbursement from Liberty Mutual for benefits paid when it was not the employer’s insurance carrier. American Home contends the court of appeals misinterpreted Iowa Code section 85.21 by concluding reimbursement claims must be resolved at the arbitration hearing involving the claimant. It further contends the court of appeals misapplied agency law by concluding American Home cannot obtain reimbursement for benefits it paid before issuance of the section 85.21 order.
Applicant
American Home Assurance
Resister
Liberty Mutual Fire Insurance Company
Attorney for the Applicant
Aaron T. Oliver
Attorneys for the Resister
Benjamin T. Erickson
Andrew D. Hall
Supreme Court
Oral Argument Schedule
15-15-5
Jan 20, 2022 1:30 PM
Briefs
Supreme Court Opinion
Opinion Number:
Date Published:
Court of Appeals
Court of Appeals Opinion
Opinion Number:
Date Published:
Summary
Appeal from the Iowa District Court for Polk County, William P. Kelly, Judge. REVERSED AND REMANDED. Heard by Vaitheswaran, P.J., Greer and Schumacher. JJ. Opinion by Vaitheswaran, P.J. (16 pages)
Liberty Mutual Fire Insurance Company (Liberty Mutual) appeals from a ruling on judicial review reversing the workers’ compensation commissioner’s decision and concluding American Home Assurance (American Home) was entitled to reimbursement from Liberty Mutual for benefits paid when it was not the employer’s insurance carrier. OPINION HOLDS: We conclude the commissioner’s interpretation of Iowa Code section 85.21 (2016) was neither “irrational, illogical, or wholly unjustifiable” nor “erroneous.” The district court judgment reversing the portion of the commissioner’s decision that declined to order reimbursement for benefits American Home paid prior to January 3, 2017, is reversed. The case is remanded for entry of a judgment consistent with this opinion.