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Hooper v. IBP11/28/2001
Appeal from the Iowa District Court for Buena Vista County, Frank B. Nelson, Judge.
Barbara and James Hooper appeal from the district court's ruling granting IBP, Inc., summary judgment on a claim for the bad faith failure as a former employer to pay medical expenses for a work-related injury. REVERSED AND REMANDED.
James Hooper appeals from a district court order granting summary judgment to IBP, Inc. on his claim for bad faith failure to pay medical bills. We reverse and remand for further proceedings.
I. Background Facts and Proceedings.
Hooper brought two workers' compensation claims against his employer, IBP, seeking benefits for physical and mental injuries sustained in the course of his employment. IBP acknowledged liability for the physical injuries but not the mental injury, asserting it was a pre-existing condition caused by other stresses in Hooper's life. Following arbitration, the deputy industrial commissioner resolved this dispute against IBP, finding as follows:
It is found that whatever the state of [Hooper's] prior psychological health might have been, it was not disabling and he was able to function and be gainfully employed at all pertinent times in his life. It is found that the pain and other stresses associated with his left shoulder injury aggravated his pre-existing condition or pre-existing susceptibility to develop depression and caused the onset of the current depressive episode . . . . The development of claimant's depression follows a logical, temporal relationship with the shoulder injury. It is further found that claimant has been totally disabled since the development of the depression in August 1991 and that he is likely to remain totally disabled by the depression indefinitely into the future.
The industrial commissioner, district court, and the court of appeals subsequently affirmed this decision.
On December 16, 1993, Hooper filed a petition requesting compensatory and punitive damages for IBP's bad faith failure to pay Hooper's medical bills. Hooper alleged that IBP's "refusal to pay the medical charges willful and intentional . . . and designed to aggravate his fragile mental health condition and [did, in fact, cause] him to suffer extreme nervousness, loss of sleep, depression and other injuries." The district court ultimately dismissed Hooper's petition, finding that the Workers' Compensation Act provides the sole remedy for all workplace injuries and that the issue of causation was barred from further litigation under the doctrine of res judicata.
On appeal Hooper contends the district court erred in granting IBP's motion for summary judgment. Specifically, he argues the Workers' Compensation Act does not bar a common law bad faith claim and the finding in the workers' compensation proceeding that his physical injuries were a substantial cause of his mental condition does not preclude a concurrent finding that IBP's refusal to pay medical bills was also a substantial cause of his illness.
II. Standard of Review.
We review a grant of summary judgment for correction of errors at law. Iowa R. App. P. 4; Whalen v. Connelly, 621 N.W.2d 681, 684 (Iowa 2000). Summary judgment is appropriate only when no genuine issue of material fact exists and the moving party is entitled to judgment as a matter of law. Iowa R. Civ. P. 237(c); Westfield Ins. Co. v. Economy Fire & Cas. Co., 623 N.W.2d 871, 876 (Iowa 2001). Here, we must determine whether the district court correctly applied the law. Whalen, 621 N.W.2d at 685. We review the record in the light most favorable to Hooper as the nonmoving party. Id.
III. Exclusivity Doctrine.
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