The Solution to the Mystery of the Overdosing Worker Whose Spouse Sought Death Benefits

Head to Part I for a refresher on the mystery.

Part II

The Clues and the Conclusion

If you selected B, you agreed with the court in Linnhaven, Inc. v. Accident Fund Nat’l Ins. Co., No. 24-0333 (Iowa Ct. App. 10/30/24), which held in the husband’s favor.

There was no doubt that a reasonable person could conclude that the employee killed herself, the court stated. The medical records indicated she was at risk of suicide and thought about it a lot. She and her boyfriend had recently split. And the note the police found read like a suicide note.

However, the court explained, the fact that a reasonable person could conclude it was suicide was not relevant. The question, instead, was whether substantial evidence supported the commissioner’s findings–not whether his findings could lead to some other conclusion.

There were a few clues that you might have picked up on that supported the commissioner’s finding that the death was an accident:

Clue #1: The suicide note

• It was found in a notebook under a stack of papers–not right beside her.
• It was undated.
• It was unfinished.

“So the commissioner could have reasonably found it merely showed [the employee] had been thinking about suicide at some point in the past—not that she intended to do so when she overdosed,” the court wrote.

Clue #2: The testimony of her son and friend

• They said she seemed to be doing well, even baking cookies the night before.
• They said on the very morning of her death, she was making plans for the near future

Clue #3: The investigation

• Neither the police nor the doctor who performed the autopsy concluded that the death was a suicide.

Under the willful injury defense, the employer had the burden of establishing that the death resulted from suicide. But the evidence as a whole, the court remarked, pointed “in both directions.” Therefore, there was substantial evidence supporting the commissioner’s conclusion that the employer failed to establish willful injury.

The appeals court affirmed the district court’s ruling awarding the husband benefits.

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