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Case No. 21-0841

Mandy Tripp
Scott Emergency Commc'n and Iowa Municipalities Workers’ Comp. Assoc.

Mandy Tripp appeals from a district court order affirming a final agency decision made by the Iowa Workers’ Compensation Commissioner. The Commissioner found Tripp did not sustain a compensable purely mental injury (“mental-mental injury”) because she did not satisfy the test for legal causation set forth in Brown v. Quik Trip Corp., 641 N.W.2d 725 (Iowa 2002). Tripp argues the Commissioner erred as a matter of law when he concluded the legal causation test for mental-mental injuries set forth in Brown is a subjective standard. Tripp further urges the supreme court to modify or overturn the Brown standard for mental injuries resulting in PTSD because the test is incompatible with modern medical understanding of PTSD and results in a harsh, unjust, and unintended denial of benefits to workers suffering from PTSD. Finally, Tripp argues the Commissioner’s decision is not supported by substantial evidence.



Mandy Tripp


Scott Emergency Commc'n and Iowa Municipalities Workers’ Comp. Assoc.

Attorneys for the Appellant

Andrew W. Bribriesco
Gabriela Navarro

Attorneys for the Appellee

Jane V. Lorentzen
Chandler M. Surrency

Supreme Court

Oral Argument Schedule


Jan 20, 2022 1:30 PM


Supreme Court Opinion

Opinion Number:
Date Published:
Jun 03, 2022
Date Amended:
Jul 08, 2022

Other Information

Date Retained:
Oct 26, 2021
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