UPDATES & ANALYSIS

3.24

Truckers must pursue workers’ compensation claims individually, not as a class, Iowa Supreme Court rules

by Rox Laird | March 24, 2020

Drivers who work for a national trucking company based in Des Moines do not have common claims for purposes of a class-action lawsuit on workers’ compensation benefits, the Iowa Supreme Court ruled March 20.

In weighing class action status in Roland v. Annett Holdings, the Court said in a 4-1 decision that whatever truck drivers employed by Annett Holdings have in common for purposes of workers’ compensation benefits is outweighed by their individual differences.

Anthony Roland sued Annett for damages after he won an administrative appeal for his own workers’ compensation benefits, which was upheld by the Polk County District Court and the Iowa Court of Appeals.

Roland subsequently sued Annett for damages, asserting on behalf of himself and 40 other out-of-state drivers for the company that a Memorandum of Understanding (MOU) the trucking company requires employees to sign violates Iowa law. The MOU forces drivers on disability to accept “light duty” assignments in Des Moines or risk suspension or termination of their benefits. In Roland’s case, that meant commuting nearly 900 miles to Des Moines from his home in Alabama.

The District Court denied Annett’s motion to dismiss the trial court’s class certification, which was upheld by the Court of Appeals. A three-judge panel for the appeals court unanimously held that the District Court’s ruling on the class action question was not an abuse of discretion.

The Supreme Court disagreed in a decision written by Justice Thomas Waterman joined by Chief Justice Susan Christensen and Justices Edward Mansfield and Christopher McDonald. Justice Brent Appel wrote a dissenting opinion in which he said the District Court should have been allowed to resolve the class action question. Justice Dana Oxley did not participate in the case.

Chapter 85 of the Iowa Code, which established Iowa’s workers’ compensation program, lies at the heart of this case. Chapter 85 states, in part, that employers are “obliged to furnish reasonable services and supplies to treat an injured employee” and that the treatment must be “reasonably suited to treat the injury without undue inconvenience to the employee.”

The trial court and appeals court both ruled that Annett’s Memorandum of Understanding violates Chapter 85, but that is true only as the MOU was applied to Roland, the Supreme Court said, not for the proposed class of drivers as a whole.

“That holding was fact-specific,” Waterman wrote. “Roland was required under the MOU to drive nearly 900 miles from his Alabama home to Iowa. The travel interfered with medical treatment, specifically with his use of the electronic cooling machine prescribed by his Alabama surgeon and his physical therapy three miles from his home, and with his visitation with his daughter.”

While the MOU “provides a common denominator to the claims of Roland and the class,” the Court said it has never held that such MOUs are per se illegal.

“We hold for class-certification purposes, the validity of the MOU must be determined driver-by-driver based on their individual factual circumstances,” Waterman wrote. “For example, drivers living in Omaha, Nebraska, or Rock Island, Illinois, on the Iowa border present different circumstances than those living in Alabama or Mississippi. The District Court erred in finding Roland satisfied the commonality requirement.

Writing for himself in dissent, Appel argued that the District Court should have been allowed to decide the class-action question as the trial suit proceeds. Roland argued that Annett’s MOU is invalid on its face, meaning the company cannot lawfully force employees to waive their workers’ compensation rights under any circumstances. His claim would be assessed by “generalized evidence,” Appel wrote, and no “particularized showing is required.”

The District Court could come to a different conclusion on the class-action as the trial proceeds, Appel wrote, but he said that should be decided at the trial-court level, without interference from the appellate courts.

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