Arias v. DURO STANDARD PRODUCTS CO.
The employee, Aisia Arias, sought workers’ compensation benefits alleging occupational asthma due to workplace dust exposure at Duro Standard Products. The trial court admitted an independent medical evaluation report from Dr. Thurman as a business record and awarded benefits. The employer appealed, contending that the report was inadmissible and that Tennessee Code Annotated section 50-6-235 was the exclusive method for introducing medical evidence. The Tennessee Supreme Court affirmed that section 50-6-235 is not exclusive but found that Dr. Thurman's report, prepared for litigation, lacked the inherent trustworthiness required for the business records exception under Tennessee Rule of Evidence 803(6). Consequently, with the report excluded, the remaining evidence was deemed insufficient to establish causation or permanency. The Supreme Court therefore vacated the trial court's judgment and dismissed the complaint.