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Michael Wilhelm, a case picker for Krogers, suffered a back and left hip injury in 2004, which he alleged was a direct result of a prior compensable Achilles tendon rupture in 1999, causing him to walk with a limp and develop Reflex Sympathetic Dystrophy (RSD). The trial court initially awarded him 35% permanent partial disability. The Special Workers’ Compensation Appeals Panel affirmed, deeming the injury idiopathic but compensable due to employment hazards. However, the higher court reversed, ruling that the 2004 injuries were not compensable as they did not arise out of employment (walking on a level, obstacle-free surface is not a special hazard). Furthermore, the court determined that the lump-sum settlement for the 1999 injury barred recovery for the subsequent complications, as they were a natural and probable result of the initial impairment and were contemplated at the time of settlement.
Wilhelm v. Krogers 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
Michael Wilhelm, a case picker for Krogers, suffered a back and left hip injury in 2004, which he alleged was a direct result of a prior compensable Achilles tendon rupture in 1999, causing him to walk with a limp and develop Reflex Sympathetic Dystrophy (RSD). The trial court initially awarded him 35% permanent partial disability. The Special Workers’ Compensation Appeals Panel affirmed, deeming the injury idiopathic but compensable due to employment hazards. However, the higher court reversed, ruling that the 2004 injuries were not compensable as they did not arise out of employment (walking on a level, obstacle-free surface is not a special hazard). Furthermore, the court determined that the lump-sum settlement for the 1999 injury barred recovery for the subsequent complications, as they were a natural and probable result of the initial impairment and were contemplated at the time of settlement.
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