This case involves a workers' compensation claim by Chad Primm against his employer, Central Sales & Service, Inc., and its insurer, stemming from a January 6, 2025, low-back injury sustained while lifting a heavy steel slab at work. Primm sought permanent total disability benefits or at least a 12% permanent partial disability rating along with temporary disability benefits, while the employer contended for only a 7% rating and the Subsequent Injury and Vocational Recovery Fund denied liability. Following a June 3, 2026, compensation hearing that considered Primm's testimony about his pain, limitations, work history, and prior medical issues, the court determined he was not permanently and totally disabled. It awarded a 7% permanent partial impairment rating and past temporary disability benefits payable by Central Sales, with no liability for the Fund. The decision rested on evaluation of the disputed impairment ratings, Primm's credibility, and the lack of evidence supporting total disability or prior qualifying injuries.
This case involved a workers' compensation claim by Jeffrey Varble against his employer AZCO, Inc., and its carrier for a left arm and elbow injury sustained at work in October 2023. The sole dispute at the compensation hearing was the amount of temporary disability benefits to which Varble was entitled. The court awarded $3,982.48 in temporary disability benefits, along with permanent partial disability benefits and open future medical benefits. The reasoning examined three contested periods of reduced hours or time off work, denying benefits for weather-related early dismissals unrelated to the injury but awarding them for days surrounding surgery and until the physician's release to full duty on January 9, 2025.
Jessie Harris, an employee placed by Express Employment Professionals at a worksite, suffered a crush injury when a crane pinned him against a tank while he performed assigned tasks. He requested specialist medical panels for pulmonology, neurology, and mental health after an authorized provider made referrals, plus temporary disability benefits. The employer initially honored one referral but later denied the entire claim, raising defenses of willful misconduct, illegal drug use, and a presumption under the Tennessee Drug-Free Workplace Program that drug use proximately caused the injury. After an expedited hearing, the court found the defenses unpersuasive, granted the panels and benefits, awarded attorney fees, and referred the employer for penalties.
This case involves Mona Toma's claim for workers' compensation benefits against The Kroger Company for an alleged gradual back and spine injury from increased inventory duties in March 2025. Kroger denied the claim on grounds that Toma failed to provide proper notice and that her symptoms related to a prior 2017 work injury for which she had settled with open medical benefits. After an expedited hearing, the court denied benefits, finding that Toma had not shown a likelihood of prevailing on the notice issue due to inconsistencies in her testimony about when and how she reported the injury to her supervisor, including whether she connected it to new job duties versus her old injury. Medical records described the symptoms as a flare-up from increased standing and bending at work without a specific acute event, and Toma's deposition indicated gradual onset but unclear reporting details. The court concluded that these evidentiary gaps prevented a finding of compensability at this stage.
This workers' compensation case involved employee Rafael Romero-Hernandez, who alleged a work-related left knee injury from a metal boom striking him in February 2024, leading to two authorized surgeries by Dr. Thomas, and claimed that subsequent right knee issues and the need for further bilateral knee surgeries were a direct consequence of overcompensation for the left knee. The employer and carrier disputed the necessity and work-relatedness of additional left knee surgery and argued the right knee condition was preexisting and unrelated. After an expedited hearing considering lay testimony, medical records from the authorized provider, a utilization review physician, and an employer's examiner, the court determined that the employee was likely to prevail on the merits regarding entitlement to medical treatment for both knees but had not shown entitlement to additional temporary disability benefits at this stage.
The case involved James Brown, an employee of the Town of Watertown, seeking workers' compensation benefits for alleged shoulder, ankle, and lower extremity injuries. The employer moved for summary judgment after requests for admissions were deemed admitted, establishing that Brown did not sustain work-related injuries and had filed a false claim. The court granted summary judgment dismissing the benefits claim because Brown failed to prove a work-related injury as required by statute, but denied the request for reimbursement of temporary disability benefits due to lack of jurisdiction. The decision relied on undisputed facts from the admissions and the requirement that the employee prove an injury arising out of employment.
labor & employmentprocedure
KM
Kenneth M. Switzer
Judge, Tennessee Court of Workers' Compensation Claims