Roy L. Tidwell, et al., v. City of Memphis

The City of Memphis promulgated an On-the-Job Injury Program to handle claims filed by city employees seeking benefits for on-the-job injuries. Thirteen firefighters and one police officer filed applications for benefits with the city. When the city denied the applications, the employees filed appeals to the On-the-Job Injury Appeals Panel which affirmed the city’s denial of benefits. Each employee appealed the panel’s determination to the Chancery Court of Shelby County by filing a Petition for Writ of Certiorari seeking review under a statutory writ of certiorari or, in the alternative, a common law writ of certiorari. The chancellor reversed the panel’s decision and held that, pursuant to section 27-9-114 of the Tennessee Code, proceedings before the panel are subject to the contested case procedures set forth in the Tennessee Uniform Administrative Procedures Act. In addition, the chancellor held that, pursuant to section 27-9-114 of the Tennessee Code, judicial review of the panel’s decision is neither by common law or statutory writ, but review must be conducted in accordance with section 4-5-322 of the Tennessee Code. The city appealed the chancery court’s ruling to this Court arguing that the chancellor erred in applying section 27-9-114 of the Tennessee Code to the panel. We reverse the chancery court’s ruling.