## Facts

- Rodney J. Schonberger, acting in the course of his employment, was driving on U.S. Highway 30 in Carroll, Iowa, to deliver his employer’s mail and return to work.
- On July 22, 1987, as Schonberger prepared to turn into his employer’s parking lot, he was struck by a truck driven by Carroll John Roberts and owned by Buck Hummer Trucking, Inc.
- Schonberger missed approximately three and one-half weeks of work and suffered neck, back, and knee injuries described as permanent, with ongoing medical needs.
- Past medical expenses totaled $7,625.40 at the time of trial; additional future medical expenses were anticipated.
- Schonberger received workers’ compensation benefits, including reimbursement for medical expenses, and his employer/insurer held subrogation rights for those payments under Iowa law.
- In the tort action, the jury apportioned fault 80% to Roberts (and the trucking company) and 20% to Schonberger, awarded $18,000 in past damages and $115,000 in future damages, and applied an additional 2% reduction based on a finding that Schonberger was not wearing a seat belt.
- Defendants sought to introduce evidence of workers’ compensation payments and paid medical expenses; the trial court excluded the evidence.

## Issues

1. Whether evidence of workers’ compensation benefits and medical expenses paid on the plaintiff’s behalf was admissible in a third-party tort action where the workers’ compensation payer had statutory subrogation rights to reimbursement from any tort recovery.
2. Whether the jury’s past and future damage awards were excessive.

## Decision

- The Iowa Supreme Court affirmed the judgment.
- The court held the trial court properly excluded evidence of workers’ compensation benefits and paid medical expenses.
- The court concluded that admitting the evidence would risk reducing the plaintiff’s recovery twice: once through a damages offset at trial and again through mandatory reimbursement via workers’ compensation subrogation.
- The court rejected the claim that the damages were excessive and upheld the jury’s awards as supported by evidence of permanent injury and future medical needs.

## Legal Principles

- When workers’ compensation benefits are subject to statutory subrogation requiring reimbursement from a tort recovery, admitting collateral-benefits evidence to reduce the verdict can create an impermissible double reduction of the plaintiff’s recovery.
- Statutes aimed at preventing double recovery should be construed to accomplish that objective once, not through overlapping mechanisms that cumulatively diminish damages beyond legislative intent.
- Under Iowa evidentiary rules, trial courts may exclude evidence as irrelevant when its admission would distort the damages determination in light of a separate statutory reimbursement mechanism.
- A damages verdict will generally be upheld when supported by evidence and within the permissible range, including for future damages based on permanent injury and anticipated medical care.

## Conclusion

The court affirmed a plaintiff’s tort verdict and approved exclusion of workers’ compensation and paid-medical-expense evidence because statutory subrogation already prevented double recovery; introducing the same payments to reduce damages would have improperly reduced the plaintiff’s recovery twice, and the jury’s damages were not excessive.


Schonberger v. Roberts, 456 N.W.2d 201 (Iowa 1990)