Michael Eberhart Construction v. Curtin

LARSON, Justice.

Iowa’s workers’ compensation commissioner awarded compensation benefits to Trampes Curtin, a former employee of Michael Eberhart Construction. The district court affirmed the award, and Eberhart and its insurance carrier, United Fire and Casualty (collectively the employer), appealed. The principal issues on appeal involve the commissioner’s (1) application of the “odd-lot doctrine,” (2) finding the claimant to be permanently and totally disabled, and (3) the district court’s denial of a lien to Eberhart on Curtin’s proceeds under an underinsured-motorist insurance policy. We…