Xenia Rural Water District v. Vegors

Xenia Rural Water District (Xenia) (defendant) employed Norman Vegors (plaintiff) as a machine inspector. Vegors and another Xenia employee, Casey Byrd, regularly acknowledged each other at work in unusual ways if their hands were full. On one occasion, Vegors had his hands full and wiggled his rear end at Byrd in acknowledgement. Vegors then turned around and leaned over the bed of his truck to focus on his work. Byrd tried to bump Vegors with the mirror of Byrd’s truck, but Byrd instead hit Vegors with the truck bed. Vegors was injured, and he sought workers’-compensation benefits from Xenia. Xenia argued that Vegors was not entitled to benefits because he had been engaging in horseplay at the time of the accident. The deputy workers’-compensation commissioner awarded benefits, holding that Xenia had the burden of proving the horseplay defense and finding that Xenia had not successfully proved the defense because Vegors was merely wiggling his rear end to communicate with Byrd and not to start or participate in horseplay. The workers’-compensation commission affirmed the award of benefits. On judicial review, the trial court found that Vegors could not recover benefits and reversed the award of benefits. The trial court disagreed with the commissioner about who bore the burden of proof on the horseplay issue, among other things. The trial court concluded that Vegors bore the burden of proving that his injury arose out of and in the course of his employment and was not the result of horseplay. Vegors appealed to the Iowa Supreme Court.