## Facts

- Walker H. Castle, a 19-year-old employee, suffered catastrophic work-related injuries, including loss of both legs at the hip joints and other severe physical losses.
- Extensive skin grafting left Castle highly sensitive to temperature changes, substantially confining him to a temperature-controlled environment.
- The employer/insurer provided workers’ compensation benefits and initially supplied Castle a laptop computer.
- Castle used the laptop for education and rehabilitation and as a substitute for abilities lost due to his confinement, including communication and interaction with the outside world.
- After the laptop stopped working, Castle sought replacement as “reasonable and necessary” care or an “appliance” under Iowa Code § 85.27 (1999).
- The employer refused, asserting a laptop is not “medical care” or an “appliance” within the statute.

## Issues

1. Whether Iowa Code § 85.27’s requirement that an employer furnish “reasonable and necessary ... appliances” can include a laptop computer for an employee whose injuries severely restrict mobility and outside interaction.
2. Whether the employer could challenge the factual basis for Castle’s asserted need for the laptop on appeal based on an allegedly incomplete administrative hearing transcript.

## Decision

- The Iowa Supreme Court granted further review, vacated the court of appeals’ contrary decision, and affirmed the district court judgment that had affirmed the industrial commissioner’s award.
- The court held that, on these facts, the industrial commissioner properly treated the laptop as a “reasonable and necessary ... appliance” under § 85.27.
- The court refused to consider the employer’s late record-based factual challenge because the employer did not seek to correct or supplement the record in the district court and had litigated the case there as a legal-only dispute.

## Legal Principles

- Under Iowa Code § 85.27, “appliances” may include nontraditional items when, considering the employee’s specific limitations, the item reasonably and necessarily restores or substitutes for a significant function impaired by the injury.
- The “appliance” inquiry is functional and context-dependent; the item’s role in offsetting injury-related loss may control over its form or whether it is a conventional medical device.
- Prior decisions treating specialized vehicles as compensable “appliances” support covering equipment that serves as a substitute for severely impaired mobility or comparable life functions.
- A party who believes the administrative record transmitted for judicial review is incomplete must raise and resolve record-correction issues in the district court; absent timely action, appellate courts may decline belated factual challenges.

## Conclusion

Because Castle’s injuries and confinement made electronic access a necessary substitute for lost physical access to the outside world, the commissioner could require the employer to provide a replacement laptop as a reasonable and necessary “appliance” under Iowa workers’ compensation law, and the employer’s untimely record objection did not warrant appellate relief.


Stone Container Corp. v. Castle, 657 N.W.2d 485 (Iowa 2003)