Iowa Code

Iowa Code § 85.71 (2026)

Injury outside of state

✓ current as of July 2026
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1. If an employee, while working outside the territorial limits of this state, suffers an injury on account of which the employee, or in the event of death, the employee’s dependents, would have been entitled to the benefits provided by this chapter had such injury occurred within this state, such employee, or in the event of death resulting from such injury, the employee’s dependents, shall be entitled to the benefits provided by this chapter, if at the time of such injury any of the following is applicable:

a. The employer has a place of business in this state and the employee regularly works at or from that place of business.

b. The employee is working under a contract of hire made in this state and the employee regularly works in this state.

c. The employee is working under a contract of hire made in this state and sustains an injury for which no remedy is available under the workers’ compensation laws of another state.

d. The employee is working under a contract of hire made in this state for employment outside the United States.

e. The employer has a place of business in Iowa, and the employee is working under a contract of hire which provides that the employee’s workers’ compensation claims be governed by Iowa law.

2. This section shall be construed to confer personal jurisdiction over an employee or employer to whom this section is applicable. [C75, 77, 79, 81, §85.71] 97 Acts, ch 106, §1; 2005 Acts, ch 168, §12, 23; 2008 Acts, ch 1091, §1; 2009 Acts, ch 179, §109; 2017 Acts, ch 23, §19, 24 \n Tue Dec 09 22:29:52 2025 Iowa Code 2026, Chapter 85 (59, 0) 37 WORKERS’ COMPENSATION, §85.72 \n

Notes of Decisions
Cited in 14 cases (1 in the last 5 years), 1979–2025 · leading case: Heartland Express, Inc. v. Terry, 631 N.W.2d 260 (Iowa 2001).
Heartland Express, Inc. v. Terry, 631 N.W.2d 260 (Iowa 2001). · cites it 48× “106, § l(codified at Iowa Code § 85.71 (Supp.1997)) (emphasis added).”
Heartland Express v. Gardner, 675 N.W.2d 259 (Iowa 2004). · cites it 82× “” See Iowa Code § 85.71 (2) (1993). Heartland contends that the post-amendment form of section 85.”
Henriksen v. Younglove Constr., 540 N.W.2d 254 (Iowa 1995). · cites it 63× “See Iowa Code § 85.71 (1989) (specifies circumstances under which injury sustained outside Iowa will be compensated under Iowa’s Workers’ Compensation Act).”
George H. Wentz, Inc. v. Sabasta, 337 N.W.2d 495 (Iowa 1983). · cites it 46× “See Iowa Code § 85.71 (2)-(4); Council of State Governments Model Act at § 7(a)(2)-(4).”
Iowa Beef Processors, Inc. v. Miller, 312 N.W.2d 530 (Iowa 1981). · cites it 26× “*532 Workers’ compensation coverage for employees engaged in employment outside the state is governed by section 85.71, The Code, which provides in pertinent part: If an employee, while working outside the territorial limits of this state, suffers an injury on account of which…”
Matthew Jahnke v. Deere & Co., Richard Czarnecki, & Bernhard Haas, 912 N.W.2d 136 (Iowa 2018). · cites it 3× “" Iowa Code §§ 85.71 -.72. This statute affirmatively states that it applies to employees injured "while working outside the territorial limits of this state" if certain circumstances are met.”
Iowa Indus. Comm'r v. Davis, 286 N.W.2d 658 (Iowa 1979). · cites it 8× “1 In two of the cases, a deputy industrial commissioner overruled Iowa Beef’s special appearances without specifying reasons; in the third case, another deputy relied upon section 85.71, The Code 1977, in similarly overruling Iowa Beef’s special appearance, because the claimant…”
Christian v. Hirschbach Motor Lines, Inc., 496 N.W.2d 270 (Iowa Ct. App. 1992). · cites it 22× “Iowa Code § 85.71 (1989). The Deputy Industrial Commissioner considered and eliminated subsection (1) because the claimant was not domiciled in Iowa and he failed to establish that his relationship, whether it be employment or otherwise, was principally located in Iowa.”
Orr v. McNair, 386 N.W.2d 145 (Iowa Ct. App. 1986). · cites it 18× “The commissioner further concluded that no reasonable construction of Iowa Code section 85.71 could support petitioner’s case.”
Annett Holdings, Inc. v. Allen, 738 N.W.2d 647 (Iowa Ct. App. 2007). · cites it 30× “Iowa Code § 85.71 . 2 The provision has been interpreted as a subject matter jurisdiction statute.”
Mike Marion Niday v. Roehl Transp., Inc. (Iowa Ct. App. 2019). · cites it 28× “2d at 519 ; see also Iowa Code § 85.71 ; Iowa Ins. Inst. v. Core Grp.”
Marie Stagg v. Dep't of Human Servs. (Iowa Ct. App. 2015). · cites it 4× “Iowa Code § 85.71 (addressing entitlement to workers’ compensation benefits for out-of-state injuries).”
— Iowa Code § 85.71(1) — 7 cases
Henriksen v. Younglove Constr., 540 N.W.2d 254 (Iowa 1995). “See Iowa Code § 85.71 (1989) (specifies circumstances under which injury sustained outside Iowa will be compensated under Iowa’s Workers’ Compensation Act).”
Iowa Beef Processors, Inc. v. Miller, 312 N.W.2d 530 (Iowa 1981). “*532 Workers’ compensation coverage for employees engaged in employment outside the state is governed by section 85.71, The Code, which provides in pertinent part: If an employee, while working outside the territorial limits of this state, suffers an injury on account of which…”
George H. Wentz, Inc. v. Sabasta, 337 N.W.2d 495 (Iowa 1983). “See Iowa Code § 85.71 (2)-(4); Council of State Governments Model Act at § 7(a)(2)-(4).”
Heartland Express v. Gardner, 675 N.W.2d 259 (Iowa 2004). “” See Iowa Code § 85.71 (2) (1993). Heartland contends that the post-amendment form of section 85.”
Orr v. McNair, 386 N.W.2d 145 (Iowa Ct. App. 1986). “The commissioner further concluded that no reasonable construction of Iowa Code section 85.71 could support petitioner’s case.”
— Iowa Code § 85.71(1)(a) — 1 case
Mike Marion Niday v. Roehl Transp., Inc. (Iowa Ct. App. 2019). “2d at 519 ; see also Iowa Code § 85.71 ; Iowa Ins. Inst. v. Core Grp.”
— Iowa Code § 85.71(1)(b) — 1 case
Mike Marion Niday v. Roehl Transp., Inc. (Iowa Ct. App. 2019). “2d at 519 ; see also Iowa Code § 85.71 ; Iowa Ins. Inst. v. Core Grp.”
— Iowa Code § 85.71(2) — 6 cases
Heartland Express v. Gardner, 675 N.W.2d 259 (Iowa 2004). “” See Iowa Code § 85.71 (2) (1993). Heartland contends that the post-amendment form of section 85.”
George H. Wentz, Inc. v. Sabasta, 337 N.W.2d 495 (Iowa 1983). “See Iowa Code § 85.71 (2)-(4); Council of State Governments Model Act at § 7(a)(2)-(4).”
Heartland Express, Inc. v. Terry, 631 N.W.2d 260 (Iowa 2001). “106, § l(codified at Iowa Code § 85.71 (Supp.1997)) (emphasis added).”
Henriksen v. Younglove Constr., 540 N.W.2d 254 (Iowa 1995). “See Iowa Code § 85.71 (1989) (specifies circumstances under which injury sustained outside Iowa will be compensated under Iowa’s Workers’ Compensation Act).”
Annett Holdings, Inc. v. Allen, 738 N.W.2d 647 (Iowa Ct. App. 2007). “Iowa Code § 85.71 . 2 The provision has been interpreted as a subject matter jurisdiction statute.”
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