Skip to main content


On April 15, 2016, the Iowa Supreme Court held that employers in workers’ compensation cases could deny liability for medical expenses incurred by employees even if they did not give notice to the employee that expenses were no longer authorized. Employers can avoid liability by demonstrating that the employee knew or reasonably should have known that such expenses were no longer authorized at the time the employee incurred them. In reaching this decision, the Iowa Supreme Court reversed two lower court decisions and the workers’ compensation commissioner. Judge Daryl L. Hecht’s dissent argued against the majority’s new “employee knowledge” standard, reasoning that it is incompatible with the clear language of the worker’ compensation statute and would therefore create confusion and uncertainty in workers’ compensation cases by upsetting the balance of interests between employers and employees that the legislature set. This Comment argues in favor of the dissent’s proposed approach because the employee knowledge standard increases the already substantial advantages employers enjoy over employees in workers’ compensation cases and is fundamentally unfair towards Iowa workers, the principal population the statute was designed to protect and benefit.


File nameDate UploadedVisibilityFile size
6 Sep 2022
341 kB



  • Subject
    • Health Law and Policy

    • Labor and Employment Law

    • State and Local Government Law

  • Journal title
    • Boston College Journal of Law & Social Justice

  • Volume
    • 37

  • Issue
    • 3

  • Pagination
    • E. Supp. 17

  • Date submitted

    6 September 2022