Nashville, Tenn. – Today the Tennessee Supreme Court reinstated workers’ compensation benefits in Edwards v. Peoplease, LLC et al. The plaintiff in the case, Jo Carol Edwards, drove a truck for Peoplease, LLC. In August 2020, one of the tires on the truck blew out, and the vehicle went down an embankment and crashed into a bridge. Ms. Edwards’ knees were injured in the crash and she applied for workers’ compensation benefits.
After multiple appeals, the Workers’ Compensation Appeals Board ultimately denied Ms. Edwards medical coverage and disability benefits, ruling that Ms. Edwards failed to counter her physician who determined her work accident did not qualify for compensation under Tennessee law.
The Tennessee Supreme Court disagreed. The Court first clarified that factual findings are reviewed without any great deference to the court below, but instead are presumed to be correct unless substantial evidence shows otherwise. As the Court explained, “aggravation” injuries are compensable under workers’ compensation law when the employee shows, by a preponderance of the evidence, that the employment contributed more than fifty percent (50%) in causing the injury, considering all causes. This requires the employee to show with expert proof (1) that a work accident caused an aggravation to the employee’s preexisting condition, and (2) that the aggravation caused the disablement or need for medical treatment. Here, Ms. Edwards was entitled to benefits because (1) her work accident aggravated a preexisting knee condition, and (2) that aggravation required her to have knee replacement surgeries.
To read the Court’s opinion in Edwards v. Peoplease, LLC et al., authored by Justice Mary L. Wagner, go to the opinions section of tncourts.gov.