Iowa Code

Iowa Code § 85.32 (2026)

When compensation begins

✓ current as of July 2026

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1. Except as to injuries resulting in permanent partial disability, compensation shall begin on the fourth day of disability after the injury.

2. If the period of incapacity extends beyond the fourteenth day following the date of injury, then the compensation due during the third week shall be increased by adding thereto an amount equal to three days of compensation. [S13, §2477-m9; C24, 27, 31, 35, 39, §1393; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §85.32] 2018 Acts, ch 1041, §127 Referred to in §85.33 \n

Notes of Decisions

Cited in 10 cases (1 in the last 5 years), 1978–2021 · leading case: Larson Mfg. Co. v. Thorson, 763 N.W.2d 842 (Iowa 2009).

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Larson Mfg. Co. v. Thorson, 763 N.W.2d 842 (Iowa 2009). · cites it 12× “See Iowa Code § 85.32 . 11 . Only one of the periods for which Thorson was awarded temporary partial disability benefits (January 8, 2000 to January 11, 2000) was within the year before the arbitration hearing.”

Mycogen Seeds v. Sands, 686 N.W.2d 457 (Iowa 2004). · cites it 2× “2d at 899 ; see also Iowa Code §§ 85.32 (“Except as to injuries resulting in permanent partial disability, compensation shall begin on the fourth day of disability after the injury.”

Clark v. Vicorp Restaurants, Inc., 696 N.W.2d 596 (Iowa 2005). · cites it 2× “809 , 825-26 (1980-81) (footnotes omitted) [hereinafter Hedberg]; see also Iowa Code §§ 85.32 , 85.33(l)-(2), 85.34(1).”

Robbennolt v. Snap-On Tools Corp., 555 N.W.2d 229 (Iowa 1996). · cites it 2× “Iowa Code section 85.32 provides in part: “Except as to injuries resulting in permanent partial disability, compensation shall begin on the fourth day of disability after the injury.”

Ellingson v. Fleetguard, Inc., 599 N.W.2d 440 (Iowa 1999). · cites it 2× “Except as provided in subsection 2 of this section, the employer shall pay to an employee for injury producing temporary total disability weekly compensation benefits, as provided in section 85.32, until the employee has returned to work or is medically capable of returning to…”

Auxier v. Woodward State Hosp.-Sch., 266 N.W.2d 139 (Iowa 1978). “33, The Code, which provides: “The employer shall pay to the employee for injury producing temporary disability and beginning upon the eighth day thereof, weekly compensation benefit payments for the period of his disability, including the increase in cases to which § 85.32…”

Christensen v. Pocket Lounge, Inc., 519 N.W.2d 401 (Iowa 1994). · cites it 2× “See Iowa Code § 85.32 (with limited exception, compensation begins on fourth day of disability after injury); Iowa Code § 85.”

Larson Mfg. Co., Inc., & Atl. Mut. Companies Vs. Julie Thorson (Iowa 2009). · cites it 12× “See Iowa Code § 85.32 . 26 when applied to cumulative injuries which develop gradually and progressively rather than suddenly, traumatically, or discretely.”

City of Maxwell & Emcasco Ins. Co. v. Dennis M. Marshall (Iowa Ct. App. 2021). · cites it 2× “to be paid on time or early. [Marshall’s] analysis of the commencement of benefits is legally inaccurate.”

Robin Lull-Gumbusky, petitioner-appellant/cross-appellee v. Great Plains Commc'n, A/K/A Great Plains Locating Servs., Inc., N/K/A Promark Consol. Util. Locators, Inc., A/K/A Iowa One Call, Employers Mut. Cas., & Com. & Indus. Ins. Co., respondents-appellees/cross-appellants. (Iowa Ct. App. 2015). · cites it 2× “He referred the parties to Iowa Code section 85.32 regarding the date for the commencement of benefits, and instructed the parties to work towards agreement on the amount of interest due.”

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