Iowa's high court just freed workers' comp employers from a costly trap: they aren't automatically bound by the opinion of the doctor they hired.
In a decision filed May 29, 2026, the Iowa Supreme Court ruled that an employer in a contested workers' compensation case is not bound by the causation opinion of the treating physician it selected, as long as a conflicting medical opinion is backed by the record.
The case centered on Jerry Hayes, a 67-year-old dishwasher hired by Ridgecrest Senior Living Center in July 2021. That September, Hayes tripped while taking out the garbage and fell onto his back. He felt fine at first, then filed an incident report eight days later and was sent for treatment.
Ridgecrest sent Hayes to Dr. Michael Dolphin, a board-certified orthopedic surgeon, who recommended a spinal fusion and a laminectomy and later assigned a 23% whole-body impairment rating. Dolphin linked the fall to Hayes's severe low back pain, calling it a substantial cause or aggravating factor.
Before approving surgery, Ridgecrest got a second opinion. Dr. Cassim Igram, also a board-certified orthopedic surgeon, compared Hayes's CT scans from 2019 with those from 2021 and found the disc herniation already present in the earlier scan. He saw no structural change and concluded the fall caused only a temporary flare-up of chronic, preexisting back pain.
It mattered that Hayes had a long back-pain history – a 1999 surgery, several car accidents, and a permanent 20-pound lifting restriction – much of which he never shared with Dolphin. Dolphin also never saw the 2019 scans. Igram did.
Hayes argued that because Ridgecrest chose Dolphin, it had to accept his causation call. The commissioner disagreed, sided with Igram, and denied permanent disability benefits. A deputy commissioner who heard Hayes testify found him not credible, saying he minimized his earlier back problems.
The Supreme Court upheld the denial. It pointed to Iowa Code section 85.39(1), which lets both sides seek another medical opinion, and emphasized that sorting out competing opinions is the commissioner's call as factfinder. The court also brushed aside Hayes's reliance on insurer good-faith cases, noting he never filed a bad-faith claim and there was a reasonable basis to deny benefits.
There was one procedural twist worth noting. The court of appeals had said Hayes forfeited his main argument by not filing a motion for rehearing at the agency. The Supreme Court disagreed, ruling that a claimant preserves an argument for appeal when the agency denies the claim and necessarily rejects that argument along the way.
The bottom line for carriers and claims professionals: authorizing a treating doctor does not give that doctor the last word on causation. A solid independent medical exam can win the day, and it is the commissioner who decides which opinion holds up.
