Iowa Supreme Court Ruling on Work Comp Shoulder Case

April 7, 2022

The Iowa Supreme Court recently released a pair of rulings dealing with the interpretation of “shoulder” in the 2017 legislation that ABI spearheaded, which made a shoulder injury a scheduled injury. 

The main ruling, Chavez v. MS Technology LLC et al., is favorable to employers because it adopts a broad definition of shoulder. This defines “shoulder” in the functional sense, which includes “the glenohumeral joint as well as all of the muscles, tendons, and ligaments that are essential for the shoulder to function.

”The claimant in Chavez had a rotator cuff injury, and challenged the commissioner and district court’s decisions that this was a “shoulder” injury. The claimant had asked the Court to adopt a narrow definition, rather than a broad one, where the shoulder would only be “located within the glenohumeral joint.” This would have limited “shoulder” to only apply to “a ball and socket synovial joint between the head of the humerus and the glenoid cavity of the scapula.”

The Court’s statutory construction and conclusion that “shoulder” must be defined in a broad, functional sense is positive news for the business community. ABI will continue to monitor this issue.

Read the ruling here.