Crouse v. Lloyd's Turkey Ranch

In Crouse v. Lloyd's Turkey Ranch, 251 Iowa 156, 159, 100 N.W.2d 115, 117 (1959), the employer raised turkeys on a farm and had a turkey processing operation on the same land. The claimant in that case was hired solely to work in the processing plant, a non-agricultural pursuit, and was injured in that pursuit. The Iowa Supreme Court found that while the employer was engaged in two occupations, the claimant was only hired to be engaged in one--the slaughter of the turkeys--and she was conducting that very activity when she was injured. Crouse, 251 Iowa at 162, 100 N.W.2d at 119. Therefore, the court concluded the exemption did not apply and she was entitled to workers' compensation benefits. See Crouse, 251 Iowa 156, 100 N.W.2d 115. In Crouse, the supreme court pointed out that the exemption's phrase, "persons engaged in agriculture," does not apply only to the employer. Crouse, 251 Iowa at 160, 100 N.W.2d at 118. The fact that the employer was engaged in agriculture was not determinative--the law examines the pursuit in which the employee is engaged. See id.