Jo Carol Edwards v. Peoplease, LLC, et al.

In this appeal, we clarify the standard of review in workers’ compensation cases. We also explain when an aggravation injury is compensable under Tennessee workers’ compensation law. Plaintiff Jo Carol Edwards sought medical coverage and disability benefits after a work-related accident aggravated her pre-existing arthritis. Following a lengthy administrative process, the Court of Workers’ Compensation Claims awarded Ms. Edwards medical coverage and disability benefits. The Workers’ Compensation Appeals Board reversed. Ms. Edwards appealed. We hold that the standard of review for factual findings in Workers’ Compensation cases is de novo on the record with a presumption of correctness unless the preponderance of the evidence shows otherwise. The standard of review for factual findings applies regardless of whether the finding is based on live testimony or deposition testimony. We also hold that an “aggravation” injury under workers’ compensation law does not require proof of a permanent change or a permanent worsening of conditions to be compensable. Instead, an aggravation injury is compensable when an employee shows, to a reasonable degree of medical certainty, that the aggravation injury primarily arose out of and in the course and scope of employment. This means that an employee must show that the employment contributed more than fifty percent in causing the aggravation. Then, the employee must prove, by a reasonable degree of medical certainty, that the aggravation contributed more than fifty percent in causing death, disablement or need for medical treatment. Applying these definitions to the record before us, we reverse the decision of the Appeals Board, and reinstate the award granted by the Court of Workers’ Compensation Claims in its December 12, 2023 Order.