Nashville, Tenn. - The Tennessee Supreme Court held today, in Brian Coblentz et al. v. Tractor Supply Company, that workers’ compensation law does not prevent an employee of a product vendor, injured on the job while at a retail store, from suing the store for his injuries.
The employee, Brian Coblentz, was employed by Stanley National, a company that sold hardware. Mr. Coblentz’s job included stocking Stanley National products in retail stores. While Mr. Coblentz was at a Tractor Supply retail store in Fayetteville, Tennessee, stocking Stanley National product in a display rack, part of the display rack fell on his head and caused him significant injuries. Mr. Coblentz received workers’ compensation benefits from his employer, Stanley National.
Mr. Coblentz filed a tort lawsuit against Tractor Supply. The lawsuit alleged that Tractor Supply was negligent and its product display rack was in “unreasonably dangerous and unsafe condition.” Tractor Supply claimed that Tennessee’s workers’ compensation laws shielded it from tort liability to Mr. Coblentz.
Under workers’ compensation law, employers must pay workers compensation benefits to employees injured on the job, regardless of fault. In exchange, the workers’ compensation law shields the employer from further claims by the employee, like tort liability.
Workers’ compensation law also says that a principal contractor who hires a subcontractor may have to pay workers’ compensation benefits to injured employees of the subcontractor, if the subcontractor does not pay benefits to its own employees. The principal contractor is then a “statutory employer,” and would have the same liability as the actual employer. In exchange for that potential liability, “statutory employers” are also shielded from tort claims by the subcontractor’s injured employees.
In this case Tractor Supply claimed it was Mr. Coblentz’s “statutory employer,” even though Stanley National had already paid Mr. Coblentz workers’ compensation benefits. As a result, Tractor Supply argued that workers’ compensation law prevented Mr. Coblentz from suing Tractor Supply. The trial court agreed with Tractor Supply and dismissed Mr. Coblentz’s lawsuit. On appeal, a majority of the Court of Appeals agreed with the trial court. The Tennessee Supreme Court granted Mr. Coblentz permission to appeal.
The Tennessee Supreme Court reversed. It held that the arrangement between Stanley National and Tractor Supply was not a contractor-subcontractor relationship; it was for product vendor Stanley National to sell merchandise to Tractor Supply. Mr. Coblentz did not do work for Tractor Supply; any services he rendered were incidental to Stanley National’s sale of merchandise to the retail store. For that reason, Tractor Supply is not Mr. Coblentz’s “statutory employer” and Tennessee workers’ compensation law does not shield Tractor Supply from Mr. Coblentz’s tort lawsuit.
To read the opinion in Brian Coblentz et al. v. Tractor Supply Company authored by Justice Holly Kirby, visit the Supreme Court opinions section of tncourts.gov.