## Facts

- Dennis L. Hanson worked as a farm employee for Sherman Reichelt during a hay-baling operation.
- The work occurred on June 24, 1983, a day with a recorded high temperature of 95°F.
- Hanson stacked approximately 60-pound hay bales and drove empty and loaded hayracks to and from the field.
- He worked for about an hour and a half and did not work more than 25 minutes without taking a break.
- Hanson stopped working, sat in the field, and was found passed out about 30 minutes later.
- He was taken to a hospital, diagnosed with heatstroke, and later died.
- Hanson’s parents, as administrators of his estate, sought workers’ compensation death benefits from Reichelt and the insurer.

## Issues

1. What causation test governs whether an element-exposure injury (such as heatstroke) “arises out of” employment: the general public–increased risk rule or the actual-risk rule?
2. Under the proper test, should Hanson’s heatstroke and death be found to have arisen out of his employment?

## Decision

- The Iowa Supreme Court rejected the general public–increased risk rule for element-exposure injuries and adopted the actual-risk rule.
- The Court declined to determine compensability on the existing record because the agency had not evaluated liability under the actual-risk standard.
- The Court affirmed in part and vacated in part the court of appeals’ decision, reversed the district court’s judgment, and remanded to the industrial commissioner for further proceedings consistent with the new rule.

## Legal Principles

- In workers’ compensation claims involving injuries from exposure to the elements, the “arise out of” requirement is governed by the actual-risk rule.
- Under the actual-risk rule, the claimant need not prove the employment exposed the worker to a greater risk than that faced by the general public; the focus is whether the employment in fact subjected the worker to the risk that caused the injury.
- The core “arise out of” inquiry is causal connection between the conditions of employment and the injury, assessed through the actual work conditions and exertion rather than public-risk comparison.
- When an agency has applied an incorrect legal standard, the proper remedy is remand to the agency to apply the correct standard as fact-finder in the first instance.

## Conclusion

The Iowa Supreme Court shifted element-exposure workers’ compensation claims from a public-comparison approach to an actual-risk causation test and remanded the heatstroke death claim for agency determination under that standard.


Hanson v. Reichelt, 452 N.W.2d 164 (Iowa 1990)