Commissioner Errs in Granting 2nd Injury Fund Credit for Worker's Prior Surgery

The Iowa Court of Appeals overturned a decision by the workers’ compensation commissioner granting a credit to the Second Injury Fund for a worker’s prior knee surgery. Case: Harrell v. Denver Findley & Sons Inc., No. 21-0827, 07/20/2022, published. Facts and procedural history: Following a 2018 foot injury, James Harrell filed a workers’ compensation petition against his employer and the Second Injury Fund. A deputy workers’ compensation commissioner found Harrell was permanently and totally disabled and that the Second Injury Fund was not entitled to a cre...