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Employer Must Provide Laptop Computer to Injured Employee Under Iowa Workers' Compensation Statute

By Francis P. Alvarez
  • March 27, 2003

In a decision that could influence courts in other jurisdictions to take a broader look at entitlements under workers' compensation statutes, the Iowa Supreme Court had held that an employer is required to provide a severely injured employee with a laptop computer as an "appliance" for treatment. The court held that the laptop computer was a replacement for the employee's own constrained ability to interact with the outside world after suffering a catastrophic industrial accident. A victory for plaintiffs seeking benefits under the Iowa Worker's Compensation Statute, the ruling expands the types of appliances employers may be required to provide to injured employees.

At the time of the accident the employee was nineteen. The catastrophic nature of the injuries required him to spend most of his time in a climate controlled room at a residential treatment facility. Although the employer initially had provided him with a laptop computer, the employer refused to replace the machine when it subsequently failed to work. The employee argued that he was entitled to the replacement since, as a result of his injuries, he was unable to access the outside world without it.

Under Iowa workers' compensation, employers must provide injured employees with reasonable and necessary "appliances" for treatment. In earlier decisions, the Iowa Supreme Court required employers to provide injured employees with vans and van modifications as replacements for their restricted mobility. The court expanded those holdings and found that, although the laptop computer did not provide the employee physical mobility, it provided him what he had lost as a result of the accident, access to the outside world. Stone Container Corp. v. Castle, No. 02/01-1291 (Iowa Feb. 26, 2003).

Editor's Note: Under the Americans with Disabilities Act and similar state laws, employers must make reasonable accommodations to qualified individuals with disabilities to enable them to perform their jobs. The ADA broadly defines "reasonable accommodation" to include "adaptive devices" and other equipment, such as computers, and employers, accordingly, have provided disabled employees with computers or particular software to enable them to work. However, this case is significant because it imports (at least in Iowa) the concept of "accommodation," which traditionally has not existed under workers' compensation laws. The case also highlights the difficulties faced by employers in managing employees' disabilities across a broad spectrum of federal and state laws. In light of this case, Iowa employers should be prepared for a broad interpretation of their obligation to provide "appliances" to injured workers.

For additional information concerning this decision, please contact the Jackson Lewis attorney with whom you regularly work or the Jackson Lewis Disability Management Practice Group.

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