Schonberger v. Roberts
456 N.W.2d 201, 1990 WL 69392, 1990 Iowa Sup. LEXIS 140 (1990)
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Rule of Law:
A court will not apply the literal text of a statute if doing so would lead to an absurd result, such as imposing a double penalty on an injured party due to the interaction of two separate statutes.
Facts:
- Rodney Schonberger was employed and driving for his job on July 22, 1987.
- While driving, he was struck by a truck driven by Carroll John Roberts and owned by Buck Hummer Trucking, Inc.
- Schonberger suffered permanent injuries to his neck, back, and knee, resulting in significant medical bills.
- He was unable to return to work for three and a half weeks following the accident.
- Schonberger began receiving workers' compensation benefits to cover his past and future medical expenses related to the accident.
- Under Iowa law, Schonberger's workers' compensation insurer has a right to be reimbursed for any benefits paid from a recovery Schonberger obtains from a third party.
Procedural Posture:
- Rodney Schonberger filed a tort lawsuit against Carroll John Roberts and Buck Hummer Trucking, Inc. in an Iowa trial court.
- At trial, the defendants sought to introduce evidence of the workers' compensation benefits Schonberger had received.
- The trial court ruled that the evidence of workers' compensation benefits was inadmissible.
- A jury returned a verdict for Schonberger, finding Roberts 80% negligent and Schonberger 20% negligent, and awarded damages.
- The defendants appealed the trial court's evidentiary ruling to the Supreme Court of Iowa.
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Issue:
Does Iowa Code § 668.14, which allows evidence of collateral source payments to be introduced in a personal injury action, permit evidence of a plaintiff's workers' compensation benefits when another statute, § 85.22, requires the plaintiff to reimburse those benefits from any tort recovery?
Opinions:
Majority - Harris, J.
No. A literal application of section 668.14 that allows the jury to hear about workers' compensation benefits would lead to an absurd result not intended by the legislature. The court reasoned that the only purpose of admitting such evidence would be to invite the jury to reduce the plaintiff's damage award. However, because section 85.22 already requires the plaintiff to repay the workers' compensation insurer from that same damage award, reducing the award based on the benefits would effectively force the plaintiff to pay twice. To avoid this double reduction, the court interpreted section 668.14's requirements as satisfied when the reimbursement provisions of section 85.22 are met, thus rendering the evidence of benefits inadmissible as irrelevant under Iowa Rule of Evidence 402.
Dissenting - McGiverin, C.J.
Yes. The clear and unambiguous language of section 668.14 states that the court 'shall permit' evidence of collateral source payments. The legislature intentionally abrogated the common law collateral source rule to allow the fact-finder to have all relevant information. The dissent argues that the proper way to avoid the inequity of a 'double reduction' is not to exclude the evidence in defiance of the statute, but to admit it and then use special jury instructions and interrogatories as provided for in section 668.14(3). The jury could be instructed that if it finds a right of subrogation exists, it may not reduce the plaintiff's recovery by the amount of those benefits. The majority's approach improperly usurps the legislative function by setting aside the clear terms of the statute.
Analysis:
This case is a classic example of the 'absurd results' doctrine in statutory interpretation, where a court deviates from the plain meaning of a statute to avoid an unjust outcome. The decision demonstrates the judiciary's power to harmonize potentially conflicting statutes to achieve a result consistent with perceived legislative intent. By creating a judicial exception to the clear language of § 668.14 in cases involving workers' compensation subrogation, the court prioritizes fairness to the injured plaintiff over literal statutory construction. This holding significantly impacts tort litigation involving injured workers by preventing defendants from using the existence of workers' comp benefits to reduce damage awards at trial, thereby preserving the integrity of the workers' compensation subrogation scheme.
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