The Iowa Supreme Court reversed a $2.84 million jury verdict in *Griffith v. Kulper*, a workplace death case involving co-employee gross negligence claims under Iowa's workers' compensation statute. The court's decision, filed Feb. 6, 2026, vacated the Iowa Court of Appeals ruling and remanded the case to district court.
Michael Griffith died in a workplace accident at Wendling Quarries after falling through an open catwalk gate into machinery. A post-accident inspection revealed that the pins required to secure the gate in a closed position were missing, creating the hazardous condition that led to Griffith's death.
Griffith's widow, Brea Anne Griffith, serving as administrator of his estate and on behalf of their minor child L.M.G., along with his father Brian Griffith, filed suit against three co-employees: John L. Kulper, Travis J. Galloway, and a third defendant. The plaintiffs alleged that the co-employees were grossly negligent and therefore liable under Iowa Code section 85.20(2), which creates an exception to workers' compensation immunity for co-employee gross negligence.
The case proceeded to trial in Iowa District Court for Benton County before Judge Kevin McKeever. After hearing evidence about the circumstances surrounding Griffith's death and the missing safety pins, the jury awarded the plaintiffs $2.84 million in damages.
The defendants appealed the judgment and the trial court's rulings denying their post-trial motions. They argued that the evidence was insufficient to establish the gross negligence standard required under Iowa law for co-employee liability.
The Iowa Court of Appeals initially affirmed the trial court judgment, finding that sufficient evidence supported the jury's verdict. However, the defendants sought further review from the Iowa Supreme Court, which granted their application.
In a unanimous decision authored by Justice Waterman, the Iowa Supreme Court concluded that the co-employee gross negligence claims failed as a matter of law. The court found that there was insufficient evidence that the defendants had the requisite actual knowledge of the specific peril that caused Griffith's death.
Under Iowa Code section 85.20(2), co-employees can be held liable for workplace injuries only when their conduct constitutes gross negligence. This standard requires more than ordinary negligence and typically involves actual knowledge of a dangerous condition combined with deliberate indifference to the safety of others.
The court's analysis focused on whether the defendants possessed actual knowledge of the specific hazard – the missing pins that should have secured the catwalk gate. Without such knowledge, the court determined that the gross negligence standard could not be met, regardless of other aspects of the defendants' conduct.
The decision represents a significant development in Iowa workplace injury law, clarifying the knowledge requirement for co-employee gross negligence claims. The ruling emphasizes that actual knowledge of the specific peril, not general awareness of workplace hazards, is necessary to overcome workers' compensation immunity.
The case involved extensive legal representation on both sides. Appellants Kulper and Galloway were represented by Matthew G. Novak and Bradley J. Kaspar of Pickens, Barnes & Abernathy in Cedar Rapids. The Griffith family members were represented by separate counsel: John C. Wagner, John Daufeldt, and Colin W. Smyka of John C. Wagner Law Offices in Amana represented Brea Griffith, the estate, and the minor child, while Cory F. Gourley of Gourley, Rehkemper & Lindholm in West Des Moines represented Brian Griffith.
The reversal means the $2.84 million judgment is set aside, and the case returns to district court for further proceedings consistent with the Supreme Court's ruling. The decision likely precludes recovery under the gross negligence theory, though the family may have other potential avenues for compensation.
The ruling underscores the protective nature of Iowa's workers' compensation system, which generally shields co-employees from personal liability for workplace injuries except in cases of gross negligence. By requiring actual knowledge of specific perils, the court maintained the narrow scope of this exception.
The case highlights ongoing challenges faced by families seeking compensation for workplace deaths when workers' compensation benefits may be insufficient to address the full scope of their losses. While workers' compensation provides certain benefits regardless of fault, the amounts are often limited compared to potential tort damages.
For workplace safety advocates, the decision emphasizes the importance of comprehensive safety protocols and clear documentation of hazard awareness to establish potential liability in cases involving co-employee negligence. The ruling may influence how employers and workers document safety concerns and communicate about workplace hazards.