A man in Iowa who was injured while helping a friend was allowed to collect benefits for his injury, because it was tied to a work related injury he sustained weeks earlier. His employer argued that the second injury was an intervening and superseding cause so they should not be responsible for medical bills resulting from that second injury.

Byran Sloan hurt his lower back at work while lifting concrete on August 15, 2011. He took a short time off for a back strain before returning to work without limitations. Six weeks after his injury he was helping a friend move go-kart frames and hurt his back again, which doctors said was a result of his first back injury. He had back surgery and reached maximum medical improvement (MMI) in January of 2013.

A deputy commissioner denied his claim because they could not find “competent medical opinions” to link his initial work injury to his second injury and determined that the go-kart accident was a superseding cause. Sloan appealed and the commissioner found that his work injury was a proximate cause of the second injury and resulting disability. They reversed the first decision, saying that moving go-karts was not a superseding cause because he was just doing a common daily activity by helping a friend and was not violating medical restrictions.

The case made its way through the system until reaching the Court of Appeals. They looked at three different medical opinions which pointed to the conclusion that his go-kart injury was a direct result of his work injury. The appellate court shut down the employer’s argument that moving the go-karts was a superseding cause of the second injury. His actions in sustaining the injury were not negligent or rash, and since he had no work limitations he was not breaking any restrictions by helping his friend move.

The employer also argued that this was an everyday activity which was unrelated to the employer’s job. The court said that if an accident occurs to an employee in the course and scope of their employment, the employer is responsible for all the consequences from that injury even if more injuries are sustained because of something outside of work.