## Facts

- Juan Mario Garcia worked as a welder for Naylor Concrete Co. on a shopping mall project in Coralville, Iowa.
- On September 30, 1997, Garcia climbed to a roof via a roughly twenty-foot ladder and traversed about ninety feet across four-inch bar joists to his work area.
- Garcia welded metal decking to joists while wearing a welding helmet with a dark lens and a tool belt weighing about thirty pounds.
- Garcia wore a safety harness, but the employer did not provide cables for tying off; the roof edge lacked barriers, warnings, or markings.
- Around 7:55 a.m., at the end of a weld line, Garcia slid off the roof edge and fell, suffering multiple fractures and being transported to a hospital.
- Evidence showed Garcia drank beer the night before; he stated he stopped by about 10:45 p.m.
- During ambulance transport, Garcia received intravenous fluids; testing at the hospital showed an alcohol concentration of 0.094 about thirty minutes after the fall.
- A toxicology expert testified the alcohol level likely would have been higher at the time of the fall and would meaningfully impair reaction time, vision, and perception, contributing to the fall.
- Garcia denied intoxication and asserted workplace hazards (unguarded edge and lack of tie-off cables) caused the accident.

## Issues

1. Whether substantial evidence supported the industrial commissioner’s finding that Garcia was intoxicated at the time of the accident under Iowa Code § 85.16(2) (1997).
2. Whether substantial evidence supported the finding that Garcia’s intoxication was a substantial factor in causing his injury, barring benefits under Iowa Code § 85.16(2).

## Decision

- The Iowa Supreme Court affirmed the district court, which had affirmed the industrial commissioner’s denial of benefits.
- The court held substantial evidence supported the finding that Garcia was intoxicated at the time of the fall.
- The court held substantial evidence supported the finding that intoxication was a substantial factor contributing to the fall, even if other unsafe conditions also contributed.
- The court relied on deference to agency fact-finding under the substantial-evidence standard and declined to reweigh credibility or competing inferences.

## Legal Principles

- Under Iowa Code § 85.16(2) (1997), workers’ compensation is barred when an injury is caused by the employee’s intoxication; “caused” requires intoxication to be a substantial factor, not the sole cause.
- On judicial review of agency action, findings of fact are binding if supported by substantial evidence when the record is viewed as a whole; courts do not reweigh evidence or reassess witness credibility.
- An employer asserting the intoxication defense bears the burden to prove intoxication and substantial-factor causation; objective testing and expert toxicology testimony may satisfy that burden.
- The presence of unsafe working conditions does not preclude application of the intoxication defense if the agency reasonably finds intoxication significantly contributed to the accident.

## Conclusion

The court upheld denial of workers’ compensation because substantial evidence supported the agency’s findings that Garcia was intoxicated and that his intoxication substantially contributed to his fall, notwithstanding evidence of workplace safety deficiencies.


Garcia v. Naylor Concrete Co., 650 N.W.2d 87 (Iowa 2002)