Vaughn v. Shelby Williams of Tennessee, Inc.
In this workers' compensation action, the employee, Barnett Vaughn, sustained a compensable back injury on September 12, 1988, while working for Shelby Williams of Tennessee, Inc. The Circuit Court of Hamblen County awarded Vaughn 80 percent permanent partial disability and temporary total disability benefits, along with a 25 percent bad faith penalty. The employer appealed, arguing that the trial court's decision was improperly based, in part, on the judge's personal observations of the plaintiff outside of judicial proceedings. The Supreme Court found this to be reversible error, stating that a judge should not base decisions on extrajudicial knowledge. The judgment of the trial court was vacated in its entirety, and the matter was remanded for a new trial before a different judge.