Wilson v. Liberty Mutual Group

NEUMAN, Justice.

The main issue on this appeal is whether a workers’ compensation claimant who settles his claim with the insurance carrier under Iowa Code section 85.35 (2001) can later prevail in an action against the carrier for bad-faith handling of the claim. The district court ruled that because the settlement required claimant to admit a bona fide dispute over the cause of his physical injury, he was estopped from asserting a contrary position in his claim for bad faith. The court also rejected claimant’s alternative claim of entitlement to judgment by default. Finding no error in…