Brown v. Liberty Mutual Insurance Co.

NEUMAN, Justice.

The United States District Court for the Northern District of Iowa has certified two questions to this court arising out of a suit for bad-faith failure to pay workers’ compensation benefits. The questions posed are as follows:

1. When does a cause of action for bad faith failure to pay workers’ compensation benefits accrue — the date the claim is denied by the insurer, the date the industrial commissioner first determines that the injury and/or disability is compensable under the Iowa Workers’ Compensation Act, or at some other time?

2. What limitation period applies to the…