P.M. Lattner Manufacturing Co. v. Rife
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In this case, the Supreme Court of Iowa reviewed a workers' compensation case involving Michael Rife, a welder who sustained two separate shoulder injuries in the course of his employment with P.M. Lattner Manufacturing Company. The first injury occurred in 2009 and compensation was determined based on Rife's loss of earning capacity. The second injury occurred in 2018, after a change in the law reclassified shoulder injuries as a scheduled disability, with compensation based on the percentage of functional impairment in relation to a set number of weeks.
The court had two main issues to address. Firstly, how to determine Rife's benefits for his second disability to prevent double recovery or reduction in benefits. Secondly, whether Rife was entitled to reimbursement for an independent medical examination he obtained while pursuing his claim for benefits.
The court held that P.M. Lattner was required to compensate Rife only for the marginal increase in the functional impairment of his right shoulder caused by the 2018 injury. In order to ascertain that amount, it must be determined whether the 19% functional impairment rating was in addition to, or inclusive of, Rife's preexisting functional impairment. The case was remanded to the district court with instructions to remand this matter to the workers' compensation commissioner to establish this.
The court further held that Rife was entitled to reimbursement for the reasonable costs of the independent medical examination to determine the impairment rating. The court affirmed the commissioner's reimbursement decision, finding that the $2,250 fee for the examination was reasonable based on substantial evidence.
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