Two weeks after the shot, his limbs atrophied and the tremors set in
An Iowa appeals court ruled a city's vaccine encouragement fell short of "strong urging," leaving one worker's severe reaction outside workers' comp.
On August 19, 2026, the Court of Appeals of Iowa affirmed a ruling that a city employee's serious reaction to a COVID-19 vaccine did not qualify for workers' compensation, because his employer's encouragement to get the shot did not amount to "strong urging."
The case centered on a water distribution manager for the City of Cedar Rapids, who worked there from 2019 until 2021. During the pandemic, the city ran a weekly employee newsletter with COVID-19 safety and vaccine updates, told staff they could use two hours of work time for a vaccine appointment, and sent emails about how sick employees were affecting operations.
After the vaccine opened to all Iowans over 16 in April 2021, the city emailed a link to a clinic at a local hospital. The manager booked through that link and got vaccinated. Two weeks later he developed an autoimmune condition that atrophied his lower limbs and left him with mobility problems, tremors, and about six months of Bell's palsy. He now spends significant time in physical therapy.
He sought workers' compensation in 2021. A deputy commissioner ruled the injury arose out of his employment. The workers' compensation commissioner reversed that award, and the district court affirmed. The appeals court affirmed as well.
The court treated the compensability of a non-mandatory vaccine injury as an issue of first impression. It agreed a treatise-based test - covering injuries where an employer applies "strong urging" for a "mutual benefit" - could fit within Iowa law. But it declined to adopt the test, finding the facts fell short either way.
What the city did, the court said, was "routine encouragement." It offered no financial incentive to get vaccinated and no penalty for declining, only a link to an off-site third-party clinic after the shot was already public. The manager's own sense of "peer pressure," the court noted, was "largely internal, not something generated by the City."
The court also weighed that the city did not collect the names of employees who used the clinic, apart from one temporary federal safety order.
One judge dissented. He pointed to a vaccine task force, eleven of thirteen newsletters urging the shot, and messaging the commissioner had called "exactly what 'strong urging' looks like." He would have adopted the test and sent the case back to the commissioner.
