An Iowa appeals court has clarified that workplace skin injuries limited to scheduled body parts are classified as “scheduled” claims, regardless of whole-person impairment ratings.
On October 29, 2025, the Iowa Court of Appeals delivered a decision that will be of particular interest to insurers and employers handling workers’ compensation claims. The case, Mecene Laguerre v. JBS USA Holdings, Inc. and American Zurich Insurance Company, centered on how to classify a workplace injury for compensation under Iowa law—a question that often impacts claim outcomes and insurance liability.
The facts of the case are straightforward but significant. Mecene Laguerre was working at a JBS meat-packing facility in Ottumwa, Iowa, when he suffered a serious injury on the job. While performing duties as a “skinner,” Laguerre was accidentally struck by a coworker wielding a mechanized knife, resulting in a degloving injury to his right arm. He was taken to the hospital, where doctors grafted skin from his right thigh to his right arm. Although Laguerre returned to work within a month, he continued to experience pain, itching, tightness, and limited range of motion in his right arm, as well as pain in his right leg.
Laguerre filed a claim for workers’ compensation benefits against JBS and its insurer, American Zurich Insurance Company. The dispute centered on whether his injury should be classified as a “scheduled” or “unscheduled” injury under Iowa Code section 85.34(2). JBS and American Zurich argued that because the injury was limited to Laguerre’s right arm and right leg—both scheduled body parts under the statute—it should be compensated according to the schedule.
Laguerre, however, pointed to the American Medical Association’s Guides to the Evaluation of Permanent Impairment, which assign a whole-person impairment rating for skin injuries, and argued that his injury should be considered unscheduled and compensated using the industrial-disability method.
Both parties presented expert testimony. JBS’s expert assigned a 9% impairment rating to Laguerre’s right arm, while Laguerre’s expert assigned a 7% whole-person impairment rating, citing scarring and functional limitations in both the right arm and right leg.
The deputy workers’ compensation commissioner ultimately found Laguerre’s expert more persuasive regarding the extent of impairment but concluded that the injury was confined to two scheduled body parts.
The commissioner held that the injury was a scheduled injury under Iowa Code section 85.34(2)(t), which covers the loss of any two scheduled body parts in a single accident, and awarded 35 weeks of permanent partial disability benefits.
Laguerre appealed, arguing that the 2017 amendment to Iowa’s workers’ compensation statute—specifically, the addition of paragraph “x” requiring the use of the AMA Guides—meant that skin injuries must be classified as unscheduled if the Guides assign a whole-person impairment rating.
The Iowa Court of Appeals rejected this argument. The court held that the statutory structure and precedent, not the AMA Guides alone, determine whether an injury is scheduled or unscheduled. The court emphasized that the statute’s focus is on the body part lost or impaired, not the specific tissue or system affected.
The court also referenced recent Iowa Supreme Court decisions reaffirming that the classification of injuries involving bodily systems or organs must be determined case by case, based on whether the injury is localized to scheduled body parts or extends to the whole body.
The court found no error in the commissioner’s decision and affirmed the denial of Laguerre’s petition for judicial review.
