## Facts

- Joseph W. Ranney III worked for Parawax Company, Inc. from 1975 to February 1981 and was exposed to toxic materials at work.
- In 1985, Ranney was diagnosed with Hodgkin’s disease.
- A 1985 physician report recorded that Ranney associated his illness with workplace exposure to paint solvents.
- Ranney suspected early that his disease might be causally connected to toxic chemicals at work and asked multiple physicians over ensuing years about a connection.
- By approximately 1987–1988, Ranney believed his disease was caused, at least in part, by chemical exposure at Parawax, though he lacked definitive medical confirmation.
- In 1991, a physician confirmed a causal link between Ranney’s disease and workplace exposure.
- Ranney filed a workers’ compensation claim in 1992 alleging work-related causation.
- The industrial commissioner granted summary judgment to the employer and carrier, finding the claim barred by Iowa Code § 85.26(1)’s two-year limitations period; the district court affirmed.

## Issues

1. When does the two-year statute of limitations in Iowa Code § 85.26(1) begin to run for a workers’ compensation claim based on a latent occupational disease under the discovery rule and inquiry-notice doctrine?
2. Does the limitations period await definitive medical confirmation of causation, or does it begin when the worker knows or should know the condition is possibly compensable?

## Decision

- The Iowa Supreme Court affirmed the district court’s judgment affirming the industrial commissioner’s summary judgment for the employer and carrier.
- The court held that the limitations period begins when the worker knows or should know the condition is possibly compensable (inquiry notice), not when a physician later confirms causation.
- Even viewing the record in the light most favorable to Ranney, the court concluded he was on inquiry notice by the late 1980s, more than two years before the 1992 filing, rendering the claim untimely.

## Legal Principles

- Under the discovery rule for latent injury in Iowa workers’ compensation, accrual occurs when the claimant has, or should have, knowledge of (1) the nature of the injury, (2) its seriousness, and (3) its probable compensable character.
- “Probable compensable character” is satisfied when facts would alert a reasonable person to the possibility that the condition is work-related and potentially compensable.
- The limitations clock is not suspended until medical certainty or expert confirmation is obtained; suspicion and known facts triggering a duty to investigate can start the period.
- Summary judgment on statute-of-limitations grounds is proper when no genuine issue of material fact exists and only one reasonable inference may be drawn from the undisputed record.

## Conclusion

The court held that latent occupational-disease claims under Iowa workers’ compensation law must be filed within two years of when the worker knew or should have known the condition was possibly compensable, and Ranney’s claim was barred because his knowledge triggered inquiry notice years before he filed.


Ranney v. Parawax Co., 582 N.W.2d 152 (Iowa 1998)