## Facts

- Lavern Steinbach applied to Polk County for general relief assistance.
- Under Iowa Code § 252.27 (1979), the county conditioned relief on repayment either in cash or by working in a county work program at the prevailing wage rate.
- Steinbach received two $75 rent vouchers for separate two-week periods.
- To repay the first voucher, Steinbach signed an agreement to work in the county’s work experience program at minimum wage for a specified number of hours.
- The county assigned Steinbach to work at a county emergency housing unit on leased premises.
- A county employee managing the premises supplied materials, directed Steinbach to wash walls and woodwork in a stairwell, and had authority to remove him for poor performance or safety concerns.
- About one-half hour after beginning, Steinbach fell over a bannister and was injured.
- The parties stipulated to the relevant events; the dispute was whether Steinbach was an “employee” for workers’ compensation purposes.
- The industrial commissioner found Steinbach was a county employee and awarded workers’ compensation benefits.
- On judicial review, the district court reversed, concluding Steinbach was not an employee.

## Issues

1. Whether a participant in a county work program performed to repay general relief assistance is an “employee” entitled to workers’ compensation benefits.
2. Whether substantial evidence supported the industrial commissioner’s finding of a “contract of hire, express or implied,” between Steinbach and Polk County.

## Decision

- The Iowa Supreme Court reversed the district court and remanded.
- The court held that a person working in a county program to repay general relief assistance may be a county employee for workers’ compensation purposes.
- The court concluded substantial evidence supported the commissioner’s finding that Steinbach worked under a contract of hire and thus qualified as an employee.

## Legal Principles

- Workers’ compensation coverage requires proof of an employee relationship, including a “contract of hire, express or implied.”
- Whether a contract of hire exists is ordinarily a fact question for the industrial commissioner.
- On judicial review, the commissioner’s fact findings are binding if supported by substantial evidence.
- In work-relief/work-experience settings, employee status turns on the specific arrangement, including:
  - an exchange of labor for wage-valued consideration (even if paid by crediting relief rather than cash), and
  - the alleged employer’s right to control the details and performance of the work.

## Conclusion

The court held that work performed to repay county general relief assistance can create an employment relationship for workers’ compensation purposes, and it reinstated (subject to remand proceedings) the commissioner’s award because substantial evidence supported a contract of hire and county control over the work.


Polk County v. Steinbach, 374 N.W.2d 250 (Iowa 1985)