Patterson Law Firm Prevails at Iowa Court of Appeals in Workers’ Compensation Case

October 29, 2025 — Des Moines, Iowa: The Iowa Court of Appeals affirmed a major win secured by Andrew Workman and Patrick Waldron of Patterson Law Firm, L.L.P. on behalf of JBS USA Holdings, Inc. and American Zurich Insurance Company in Laguerre v. JBS USA Holdings, Inc., No. 24-2049.

The case involved an employee who sustained a “degloving” skin injury to his arm and a skin graft from his leg, which yielded a whole person impairment rating under the skin chapter of the AMA Guides. The key issue was whether the injury qualified as a scheduled or unscheduled injury under Iowa Code section 85.34(2). The claimant argued that because skin is not listed in the statute and is rated in the AMA Guides as a whole-person impairment, all non-face-or-head skin injuries must be treated as unscheduled.

Patterson Law Firm successfully argued that long standing precedent and the statutory structure required the injury to be limited to the schedule, since it was confined to two body parts—the arm and leg—specifically enumerated in the statute. The Court of Appeals agreed, holding that paragraph “x” of section 85.34(2), which mandates use of the AMA Guides, governs the extent of impairment, not whether an injury is scheduled or unscheduled.

In affirming the district court and the Iowa Workers’ Compensation Commissioner, the Court emphasized that the 2017 statutory amendments did not overturn settled precedent and reaffirmed the case-by-case approach to determining whether bodily-system injuries like those to the skin are scheduled or unscheduled.

This decision strengthens Iowa employers’ and insurers’ ability to rely on established law governing scheduled-member injuries and reaffirms Patterson Law Firm’s record of success in complex statutory interpretation and appellate advocacy.