The Iowa Supreme Court affirmed a district court ruling that the state's workers compensation commissioner incorrectly applied Iowa's discovery rule in deciding that an employee's workers comp claim was time-barred under the statute of limitations.

Under Iowa law, the statute of limitations for a workers comp claim can be extended based on the discovery rule, which requires that the injured worker have actual or imputed knowledge of the nature, seriousness and probable compensation of the injury or disease before the statute of limitations period begins.

According to the court record in Bruce Baker vs. Bridgestone/Firestone and Old Republic Insurance, Mr. Baker had worked for the company since 1994, serving as a maintenance mechanic at its Des Moines, Iowa, plant, when he sustained a back injury in May 2010. He experienced pain in his lower back and immediately reported the incident to a supervisor as required by company policy. Mr. Baker resumed working after being examined by the plant physician, who recommended stretching exercises and instructed Mr. Baker to use acetaminophen and ice for his discomfort.

On the second anniversary of the incident in May 2012, the manufacturer notified Mr. Baker that the statute of limitations period had expired and no further medical services would be provided for treatment of his injury, according to court documents.

In June 2012, Mr. Baker petitioned the Iowa Workers' Compensation Commission seeking both temporary and permanent benefits for his back injury, but a deputy workers comp commissioner ruled that Mr. Baker did not sustain a cumulative injury and that he knew or should have known his condition was serious, according to court documents. The deputy did not dispute Mr. Baker's testimony that he did not anticipate the permanent nature of his injury, but concluded this did not matter because the discovery rule only applied to cumulative injuries — a decision affirmed in an interagency appeal to the commissioner.

The Iowa District Court for Polk County reversed the commissioner's ruling, concluding the discovery rule can apply to injury claims arising from singular events, and remanded the case to the agency for a decision on whether the discovery rule extended Mr. Baker's time to file for benefits.

Bridgestone appealed the district court's decision, and the Iowa Supreme Court stepped in to decide whether the discovery rule could apply to determining when the period of limitation commences for workers comp claims arising out of a singular event. The Supreme Court on Friday disagreed with the company and the commissioner in affirming the district court's decision and remanding the case back to the commission.

“Whether a work-related injury arises because of a single event or develops cumulatively over time, the discovery rule applies in determining whether a workers' comp claim has been filed within two years after the occurrence of the injury,” the Supreme Court said in its decision. “That limitation period does not begin to run until the claimant knows or in the exercise of reasonable diligence should know 'the nature, seriousness and probable compensable character' of his or her injury.”

Lawyers for the company and the insurer did not immediately respond to requests for comment.

Mr. Baker's attorney, Martin Ozga of Neifert, Byrne & Ozga P.C. in West Des Moines, Iowa, said in an email that the Supreme Court in Baker simply reinstated the rule that had been in place since it recognized the discovery rule in Orr v. Lewis Central School District in 1980. That case applied the discovery rule to a situation where there had been a traumatic injury, he said.

It was only with the commissioner's decision in a case called Clark v. City of Spencer that the commissioner concluded that the discovery rule did not apply to traumatic injury situations, which Mr. Baker's attorney argued was inconsistent with Orr and other Supreme Court cases where the court had applied the discovery rule to traumatic events.

“Although the case may allow additional claimants to obtain workers' compensation benefits, they still must prove when they know the nature, seriousness and probable compensable character of their injury,” Mr. Ozga said.