## Facts

- Frank Guyton, Jr., an employee of Irving Jensen Company, was injured on May 5, 1978, when a cement truck struck his left hip, causing a back injury.
- He received workers’ compensation benefits for about three months in 1978.
- Guyton later filed a review-reopening petition under Iowa Code § 85.26(2) seeking additional benefits, alleging permanent and total industrial disability.
- A deputy industrial commissioner found Guyton had a 20% industrial disability to the body as a whole and awarded benefits accordingly.
- The district court affirmed on judicial review; the court of appeals reversed, holding total disability was proven as a matter of law.
- On further review, the supreme court considered whether the commissioner used the correct legal standard for industrial disability and whether the record compelled a total-disability finding.

## Issues

1. Whether the industrial commissioner applied an incorrect legal standard by failing to apply the odd-lot doctrine when evaluating alleged total industrial disability.
2. Whether the evidence required a finding of total industrial disability as a matter of law, making the commissioner’s 20% finding unsustainable.

## Decision

- The supreme court adopted the odd-lot doctrine for Iowa workers’ compensation cases.
- The court held the commissioner erred as a matter of law by not applying the odd-lot framework and by narrowing the inquiry to what the claimant could or could not do, rather than realistic employability.
- The court rejected the court of appeals’ holding that total disability was established as a matter of law; the extent of industrial disability remained a fact question for the commissioner under the correct standard.
- The court vacated the court of appeals decision, reversed the district court, and remanded to the industrial commissioner for further proceedings consistent with the odd-lot doctrine.

## Legal Principles

- Industrial disability is an economic and vocational concept; it is not limited to medical or functional impairment and includes the claimant’s ability to obtain gainful employment in the competitive labor market.
- Under the odd-lot doctrine, a worker may be deemed totally disabled if, despite some capacity for work, the worker’s physical limitations and vocational factors make regular employment in a stable labor market unrealistic.
- A claimant who makes a prima facie showing of odd-lot status (such as substantial limitations combined with adverse vocational factors and bona fide but unsuccessful efforts to find work) shifts the burden to the employer to show suitable work is regularly and continuously available.
- Appellate courts generally defer to the commissioner’s fact-finding on degree of disability, but reversal is required when the commissioner applies an incorrect rule of law.

## Conclusion

The court required Iowa workers’ compensation adjudicators to apply the odd-lot doctrine, including its employability focus and burden-shifting method, and remanded for reconsideration because the commissioner used an incomplete legal standard; the record did not compel a total-disability finding as a matter of law.


Guyton v. Irving Jensen Co., 373 N.W.2d 101 (Iowa 1985)