The Iowa Supreme Court recently ruled in a workers' compensation case that could impact how impairment ratings are calculated for injured workers. The court's decision affects Brian Dale Klein, an employee of Whirlpool Corporation, who sought further review after his claim was dismissed by lower courts. This ruling clarifies how the American Medical Association (AMA) Guides should be applied in determining disability ratings.
The case, Brian Dale Klein v. Whirlpool Corporation, was filed on June 26, 2026, under docket number 25-0458. Klein injured his right shoulder while working at Whirlpool and later underwent surgery that included a distal clavicle excision. The dispute arose over the extent of his permanent disability and the impairment rating assigned to it.
Initially, three physicians provided impairment ratings for Klein's injury. Dr. Matthew Bollier assigned a 4% impairment, while Dr. Robert Broghammer assigned a 2% impairment, both based on loss of range of motion. Dr. Mark Taylor, however, assigned a 6% impairment for loss of range of motion and an additional 10% for the distal clavicle excision. This led to a total impairment rating of 15% according to Dr. Taylor's assessment.
Despite this, the deputy commissioner did not accept the full 15% rating. Instead, they relied on a prior decision that required the 10% impairment for the distal clavicle excision to be reduced by a 25% multiplier, resulting in an overall impairment rating of 9%. Klein's petition for judicial review was denied by the district court, and the court of appeals affirmed this decision.
Upon further review, the Iowa Supreme Court found that the commissioner had incorrectly interpreted the AMA Guides. The court highlighted a previous ruling in a similar case, Koeller v. Cardinal Logistics Management Corp., where they clarified that the AMA Guides already provided a specific impairment value for a distal clavicle excision. As a result, the court ruled that the additional conversion under the multiplier was not applicable in this case.
The court ruled, "Because Table 16-27 already gives an upper extremity impairment value, the additional conversion under Table 16-18 is not made. The specifics in section 16.7b of the AMA Guides prevail over the general statement in section 16.7."
As a result of this ruling, the Iowa Supreme Court vacated the decision of the court of appeals and reversed the district court's judgment. They instructed the district court to remand the case back to the workers' compensation commissioner for further proceedings consistent with their opinion.
This ruling is significant as it clarifies how impairment ratings should be calculated for workers' compensation claims in Iowa. It emphasizes the importance of adhering to the specific guidelines set forth in the AMA Guides, which can directly impact the benefits injured workers receive. The decision may also set a precedent for future cases involving similar disputes over impairment ratings.
Going forward, this ruling may affect not only Klein but also other workers in Iowa seeking fair compensation for their injuries. It underscores the need for accurate interpretations of the AMA Guides in determining impairment ratings, which can significantly influence the outcome of workers' compensation claims.
Details were not available in the court filing regarding whether the case could be further appealed or if there are related cases pending. However, the court's ruling provides clear guidance on how similar cases should be handled in the future.