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James E. Carpenter, a Tennessee Army National Guard member, was injured in 1985. He received federal incapacitation pay and medical expenses, and state Medicaid benefits. His workers' compensation claim, filed in 1987, was dismissed by the Claims Commissioner as time-barred by the one-year statute of limitations. Carpenter appealed, arguing that these payments tolled the statute or that equitable estoppel applied. The Supreme Court of Tennessee affirmed the dismissal, ruling that neither federal nor state benefits qualified as 'voluntary payments of compensation' to toll the statute, and found no affirmative conduct by the state to support equitable estoppel.
Carpenter v. State is a workers' compensation case decided in Tennessee Supreme Court. This case addresses legal issues related to compensation claims, benefits, and court rulings.
It is commonly referenced in legal research involving workers' compensation laws in Tennessee Supreme Court.
Full Decision Text1 Pages
James E. Carpenter, a Tennessee Army National Guard member, was injured in 1985. He received federal incapacitation pay and medical expenses, and state Medicaid benefits. His workers' compensation claim, filed in 1987, was dismissed by the Claims Commissioner as time-barred by the one-year statute of limitations. Carpenter appealed, arguing that these payments tolled the statute or that equitable estoppel applied. The Supreme Court of Tennessee affirmed the dismissal, ruling that neither federal nor state benefits qualified as 'voluntary payments of compensation' to toll the statute, and found no affirmative conduct by the state to support equitable estoppel.
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