Roy L. Tidwell and Richard Coggins, et al. v. City of Memphis

This case involves an appeal filed by thirteen firefighters and one police officer currently or previously employed by the City of Memphis. Each of the employees was diagnosed with an illness or condition claimed to be work-related. After the City of Memphis denied the employees’ claims for benefits stemming from their work-related conditions, the employees appealed to the Chancery Court of Shelby County. The chancery court consolidated the cases, reversed the City’s denial of benefits, and awarded benefits to each of the employees. The chancery court’s decision was based upon its determination that the cases should have proceeded under the Uniform Administrative Procedures Act “UAPA” rather than an alternative process adopted by the City to handle such claims. The Court of Appeals reversed, finding that the City was not required to comply with the UAPA in resolving claims for work-related benefits. After careful consideration of the record and applicable law, we conclude that the chancery court correctly determined that the employees’ cases were subject to the contested case procedures set forth in the UAPA. Accordingly, the judgment of the Court of Appeals is reversed. We also reverse the trial court’s judgment to the extent that it awards benefits to the employees. The case is remanded to the trial court for further proceedings pursuant to this opinion.