Hanson v. Reichelt

LAVORATO, Justice.

This appeal arises out of the death of a farm employee who suffered a heatstroke while working. The Iowa industrial commissioner denied benefits, finding that the employee’s injury did not arise out of his employment. In making this finding, the commissioner applied the general public-increased risk rule, a rule this court first approved in a workers’ compensation case involving heatstroke more than fifty years ago.

The district court affirmed the commissioner’s decision. The administrators of the deceased employee’s estate appealed; we transferred the case to the court of…