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Humboldt Community Schools v. Fleming12/22/1999
, this claimant cannot recover because the death of her husband was self-inflicted. (Dunlavey did not involve a self-inflicted injury.) Iowa's workers' compensation law does not provide benefits for an injury caused " y the employee's willful intent to injure the employee's self or to willfully injure another." Iowa Code § 85.16(1). Prior to 1993 suicide was only compensable if the "mental condition of decedent at the time of the suicidal act was such that he was motivated by an uncontrollable impulse or in a delirium of frenzy, without conscious volition to produce death." Schofield v. White, 250 Iowa 571, 581, 95 N.W.2d 40, 46 (1959). No such showing was made in this case. However, the stringent test of Schofield has been abandoned. In Kostelac v. Feldman's, Inc., 497 N.W.2d 853 (Iowa 1993), we held suicide would be compensable on proof of causation directly linking an employment injury to a worker's loss of normal judgment and domination by a disturbance of the mind. Kostelac, 497 N.W.2d at 856-57.
Humboldt Schools argues that the chain-of-causation test under Kostelac requires that a job -related injury was caused by a "deranged mental state which, in turn, caused the suicide," citing Kostelac, 497 N.W.2d at 857. The basis of the schools' argument is that in Kostelac we cited 1A Arthur Larson, The Law of Workmen's Compensation § 36.00 (1985) [hereinafter Larson], which said "if the will itself is deranged and disordered" causation may nevertheless be found in suicide cases.
The term "derangement," we believe, is too nebulous to adopt as a prerequisite to recovery. One dictionary defines derange as to "disarrange," to "put out of place or order," or "to disturb the operation or function of . . . ." Webster's Third New International Dictionary 607 (unabr. ed. 1986). The closest this dictionary definition comes to describing a mental condition is to say deranged means "crazy" or "insane," id., terms that are themselves too broad to be of any usefulness for our purpose.
Professor Larson suggests that "derangement," as used in the causation test adopted by us in Kostelac, is not a psychiatric term of art but is a general term similar to "disordered," as evidenced by the fact he uses the words simultaneously:
If the sole motivation controlling the will of the employee who knowingly decides to commit suicide is the pain and despair caused by the injury , and if the will itself is deranged and disordered by these consequences of the injury, then it seems wrong to say that this exercise of will is "independent," or that it breaks the chain of causation. Rather, it seems to be in the direct line of causation. 2 Arthur Larson, Larson's Worker's Compensation Law § 38.03, at 38-13 (1999) (emphasis added) (citing Whitehead v. Keen Roofing Co., 43 So. 2d 464, 465 (Fla. 1949)).
Most important, Kostelac's causation test does not require a showing of derangement. It says:
We are persuaded that this shift in emphasis from proof that an employee acted in an impulsive, frenzied state to proof that but for an employment-related mental injury —however experienced—the employee would not have committed suicide, is a more sound way of dealing with the "willful injury" issue of [Iowa Code] section 85.16(1). Kostelac, 497 N.W.2d at 857.
We conclude the industrial commissioner and the district court applied the correct legal test under Kostelac for avoiding the self-imposed-injury defense of Iowa Code section 85.16(1) and properly refused to require a showing of derangement.
V. Sufficiency of the Evidence.
In a "mental/mental" injury case (a mental injury without an accompanying physical injury), a claimant must show both a
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