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January 10, 2012

Iowa: Employee Bowling League Injury Not Work-Related

Extensively citing Larson’s definitive work on Workers’ Compensation, the Iowa Court of Appeals found that an employee who is injured in a company bowling event is not entitled to workers’ compensation benefits, reversing the finding of the Iowa Workers’ Compensation Commissioner. On June 11, 2005, while participating in a bowling event organized by the employee activity committee of Gazette Communications, Robert Powell was injured, and asserted that this was a work injury. The Iowa Supreme Court had previously held that a heart attack in the course of an employee basketball league was a covered work injury.


Powell relied on a 1984 decision of the Iowa Supreme Court, Briar Cliff College v. Campolo, 360 N.W.2d 91, 94 (Iowa 1984), which found that a fatal heart attack sustained by a Professor at Briar Cliff College while playing intramural basketball on college property was work-related. In that case, the college administration had encouraged college faculty to take part in intramural sports, to interact with students. Relying on “Larson’s business-related benefit test,” articulated in Larson’s Workers’ Compensation, the Iowa Supreme Court found that Professor Campolo’s participation in the intramural game provided a direct benefit to Briar Cliff College, in the recruitment and retention of students.


The Campolo decision and heart attacks at work in Iowa are discussed in more detail in an article of the Drake Law Review, “INSURANCE LAW ANNUAL: When Are Heart Attacks Compensable Injuries Under Iowa Workers’ Compensation Law?”, 49 Drake L. Rev. 621 (2001). The Commissioner relied on the Campolo decision to award benefits. However, in the present case, the Iowa Court of Appeals distinguished that decision, noting that Gazette Communications did not derive any benefit other than increased employee morale. The Iowa Court of Appeals applied the standard set out at 2 Arthur Larson & Lex K. Larson, Larson’s Worker’s Compensation Law § 22.01, at 22-2 (2010), that the activity giving rise to the injury must provide some specific benefit to the employer, beyond “the intangible value of improvement of employee health and morale that is common to all kinds of recreation and social life.”

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