Hawkins v. Bleakly, Auditor of the State of Iowa, Et Al.

Background

An Iowa employer sued in federal court to stop enforcement of Iowa’s 1913 workmen’s compensation law, after rejecting the law’s compensation terms. The District Court dismissed the suit. The Iowa Supreme Court had earlier upheld the law and interpreted key provisions, and the federal Court accepted that state construction. The statute covers most employments (excluding household servants, farm laborers, and casual employees) and presumes acceptance by employers and employees unless either gives notice rejecting the law.

Reasoning

The core question was whether the State could adopt that compensation scheme and certain special rules without violating the federal Constitution. The Court held the State may do so: employers have no vested right to keep old common-law defenses; the State may create presumptions and shift burdens of proof; protections that void an employee’s rejection if the employer improperly influenced them are permissible; and administrative procedures with an arbitration committee and an Industrial Commissioner, together with judicial review of fundamental questions, satisfy due process. The Court also rejected arguments that jury trial protections or an alleged Northwest Territory guarantee blocked the law, and found no unlawful discrimination in the challenged classification. The Court declined to decide compulsory-insurance questions because the appellant had not accepted the act.

Real world impact

The decision leaves Iowa’s compensation framework in place for most workplaces. Employers who reject the act may be denied certain common-law defenses; accepted claims proceed through administrative hearings with limited judicial review. The decree was affirmed, so the law stands as interpreted by the Iowa Supreme Court.