Guyton v. Irving Jensen Co.
1985 Iowa Sup. LEXIS 1122, 373 N.W.2d 101 (1985)
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Rule of Law:
In workers' compensation cases, the 'odd-lot doctrine' is adopted, establishing that a worker is totally disabled if their injury makes them incapable of obtaining employment in any well-known branch of the labor market such that a reasonably stable market for their services does not exist. If a worker makes a prima facie case for inclusion in the odd-lot category, the burden of producing evidence of suitable employment shifts to the employer.
Facts:
- Frank Guyton, Jr. injured his back on May 5, 1978, while working for Irving Jensen Company in Sioux City when he was struck in the left hip by a cement truck.
- Guyton is approximately 40 years old, a Black man, with about one month of formal education, and cannot read, write, or make change; psychological tests showed him to be mildly retarded, limiting him to unskilled, repetitive jobs requiring no literacy.
- Before his injury, Guyton's employment history included work as a farm hand, fertilizer bagger, bottling plant laborer, city garbage man, janitor, and highway construction laborer.
- Medical evidence indicated Guyton suffered a lower back sprain resulting in a permanent physical impairment of 15-20% of the body, preventing him from doing jobs on a regular basis that involved bending, prolonged sitting, or lifting as little as ten or fifteen pounds.
- After his injury, a vocational counselor concluded Guyton had 'little, if any, possibility of job placement in substantial gainful activity' due to his physical and mental limitations, rating him 100% vocationally disabled.
- Guyton made substantial efforts to find employment for more than four years in the Waterloo area and up to 150 miles away but found no jobs, subsisting by earning small amounts through 'junking' activities and social security disability compensation.
Procedural Posture:
- Frank Guyton, Jr. filed a petition for review-reopening with the industrial commissioner seeking benefits for permanent disability.
- The industrial commissioner, acting through a deputy, determined Guyton's disability to be twenty percent.
- Guyton filed a petition for judicial review with the district court, which affirmed the commissioner's decision.
- Guyton appealed to the Iowa Supreme Court, which transferred the case to the court of appeals.
- The court of appeals reversed the district court, holding that Guyton proved total disability as a matter of law.
- Irving Jensen Company (the employer) filed a petition for further review with the Iowa Supreme Court.
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Issue:
Does the 'odd-lot doctrine,' which considers a worker totally disabled if their injury and personal characteristics render them unemployable in the competitive labor market and shifts the burden of production to the employer, apply in Iowa workers' compensation cases for determining industrial disability?
Opinions:
Majority - McCormick, Justice
Yes, the "odd-lot doctrine" applies in Iowa workers' compensation cases, and the industrial commissioner erred by not applying it and by equating Guyton's ability to perform physical activity with his ability to obtain employment, thus misapplying the law. The court formally adopted the "odd-lot doctrine," which clarifies that a worker is totally disabled if their injury makes them incapable of obtaining employment in any well-known branch of the labor market, such that a reasonably stable market for their services does not exist. While the burden of persuasion on industrial disability remains with the worker, the burden of production shifts to the employer if the worker makes a prima facie case of total disability by producing substantial evidence that they are not employable in the competitive labor market. The industrial commissioner had incorrectly focused solely on Guyton's ability to perform physical activity (e.g., his 'junking' activities) rather than considering all factors bearing on his actual employability, including his age, intelligence, education, qualifications, experience, and the effect of the injury on his ability to obtain suitable work. The court found that Guyton had clearly made a prima facie case for inclusion in the odd-lot category, but the evidence was not so strong as to compel a finding of total disability as a matter of law. Therefore, the court vacated the decision of the court of appeals, reversed the district court, and remanded the case to the industrial commissioner to apply the newly adopted doctrine and allow parties to offer additional evidence on the availability of suitable employment for Guyton.
Analysis:
This case significantly shaped Iowa workers' compensation law by formally adopting the 'odd-lot doctrine' and defining how industrial disability should be assessed. It moves the focus beyond mere physical impairment to a more comprehensive evaluation of a worker's actual employability, considering personal characteristics like education, age, and intelligence alongside their injury. The introduction of a burden-shifting mechanism places a substantial responsibility on employers to demonstrate the availability of suitable work once a worker presents a strong prima facie case for unemployability. This ruling ensures that workers with severe combined physical and socio-economic barriers to employment are more likely to receive a finding of total disability, preventing situations where limited physical capacity is mistakenly equated with employability.
