Workers’ Comp Claim Timeliness

Read­ing Time: < 1 minute

Last Updat­ed on Jan­u­ary 2, 2024 

Iowa Supreme Court Rules on Workers’ Comp Claim Timeliness: “Knowing is Half the Battle”

Case Back­ground: An Iowa farm work­er injured his right elbow while vac­u­um­ing grain and under­went surgery for a sub­se­quent shoul­der tear. The work­ers’ com­pen­sa­tion car­ri­er denied his claim based on the two-year statute of lim­i­ta­tions, argu­ing he knew of the injury more than two years before filing.

Legal Issue: Did the “dis­cov­ery rule,” which delayed the start of the lim­i­ta­tions peri­od until the work­er knew the injury was seri­ous enough to affect his employ­ment, apply in this case?

Hold­ing: No, the dis­cov­ery rule was abol­ished by a 2017 amend­ment defin­ing “date of occur­rence of injury” as the date the employ­ee knew or should have known the injury was work-related.


  • The amend­ed law elim­i­nat­ed the need for a sep­a­rate dis­cov­ery rule by explic­it­ly stat­ing when the time lim­it starts.
  • The court inter­pret­ed the leg­is­la­ture’s intent as set­ting a clear bench­mark for fil­ing claims, regard­less of the injury’s severity.
  • In this case, the work­er knew or should have known his elbow injury was work-relat­ed over two years before fil­ing, mak­ing his claim untimely.


  • This deci­sion sim­pli­fies the statute of lim­i­ta­tions by remov­ing the uncer­tain­ty of the dis­cov­ery rule’s “per­ma­nent adverse impact” test.
  • Work­ers must be more proac­tive in fil­ing claims if they know or sus­pect a work-relat­ed injury, even if its seri­ous­ness is unclear.
  • Employ­ers ben­e­fit from increased clar­i­ty and pre­dictabil­i­ty in deter­min­ing claim timeliness.

Additional Notes:

  • The case also addressed the work­er’s claim for reim­burse­ment of his inde­pen­dent med­ical exam­i­na­tion (IME) costs. The court upheld the low­er court’s deci­sion to award reim­burse­ment based on sub­stan­tial evi­dence sup­port­ing the IME’s value.
  • This case serves as a reminder for work­ers and employ­ers to under­stand the legal require­ments sur­round­ing work­ers’ com­pen­sa­tion claims, par­tic­u­lar­ly the revised statute of limitations.

Have You’ve Been Injured on the Job?

No Obligation — Confidential — FREE CONSULT


Call Now