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LIGHT v. SECOND INJURY FUND OF IOWA5/31/2002
barred by claim preclusion. Light appeals.
II. Standard of Review. We review a district court's ruling on judicial review of a workers' compensation case for correction of errors of law. Blanchard v. Belle Plaine/Vinton Motor Supply Co., 596 N.W.2d 904, 906 (Iowa Ct. App. 1999). Our review is limited to whether the district court correctly applied the law in exercising its judicial review function. IBP v. Harpole, 621 N.W.2d 410, 414 (Iowa 2001). In determining whether the law has been correctly applied, we are bound by the workers' compensation commissioner's factual findings if they are supported by substantial evidence in the record. Id. Evidence is substantial if a reasonable mind would accept it as adequate to reach the same conclusion. St. Luke's Hosp. v. Gray, 604 N.W.2d 646, 649 (Iowa 2000).
III. Merits. Light contends the district court erred in holding the workers' compensation commissioner committed an error of law by allowing her to litigate on the merits her second claim against the Fund. We agree.
"Res judicata as claim preclusion applies when a litigant has brought an action, an adjudication has occurred, and the litigant is thereafter foreclosed from further litigation on the claim." Israel v. Farmers Mut. Ins. Ass'n of Iowa, 339 N.W.2d 143, 146 (Iowa 1983). "Claim preclusion bars further litigation on the same claim or cause of action . . ." Leuchtenmacher v. Farm Bureau Mut. Ins., Co., 460 N.W.2d 858, 860 (Iowa 1990). "A cause of action is the same when the asserted invasion of rights is the same." Westway Trading Corp. v. River Terminal Corp., 314 N.W.2d 398, 401 (Iowa 1982). To determine "whether the cause of action is the same, we examine the protected right, the alleged wrong, and the relevant evidence." Id. Claim preclusion is based on the principle that a party may not split or try his claim piecemeal, but must put in issue and try his entire claim or put forth his entire defense in the case on trial. An adjudication in a former suit between the same parties on the same claim is final as to all matters which could have been presented to the court for determination. A party must litigate all matters growing out of his claim at one time and not in separate actions.
Iowa Coal Mining Co. v. Monroe County, 555 N.W.2d 418, 441 (Iowa 1996) (citations omitted).
The Fund argues Light's 1997 hearing "involved substantially the same evidence as the later hearing . . ." See B & B Asphalt Co. v. T.S. McShane Co., 242 N.W.2d 279, 287 (Iowa 1976) (holding "identity of cause of action is established when the same evidence will maintain both actions"). "However, the right to join related claims does not bar subsequent litigation of a distinct claim that was not joined." Leuchtenmacher, 460 N.W.2d 858 at 860 (citing Westway, 314 N.W.2d at 401). Because Light's first and second Fund claims are distinct and different, claim preclusion does not bar the second claim which is the subject of this case.
Light's first claim against the Fund sought compensation for the combined effects of a 1974 right leg injury and a 1993 left hand injury. In contrast, her second claim against the Fund seeks compensation for the combined effects of the 1993 left hand injury and the 1994 leg injury. While the agency considered some of the same evidence in the two Fund hearings, distinctly different injury combinations and accordingly different industrial disability claims were alleged and decided. Light's two Fund claims do not allege the same "natural grouping or common nucleus of operative facts" nor are they "so woven together as to constitute a single claim." See Leuchtenmacher, 460 N.W.2d at 860 (quoting Restatement (Second) of Judgments ยง 24 cmt. b).
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