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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Cortrim Manufacturing Co. v. Smith

The plaintiff sought death benefits under the Workmen’s Compensation Act for her husband’s death, alleging a causal connection between his employment activities and his fatal heart attack. The defendant appealed the trial court's decision, challenging the admissibility of a hypothetical question posed to a heart specialist and the finding of a causal link. The court affirmed the Chancellor's decree, ruling that the trial court did not err in overruling the objection to the hypothetical question. Furthermore, it concluded that sufficient evidence supported the finding that the decedent's physical activity and exertion at work precipitated his fatal heart attack, even with a pre-existing heart condition.

Workers' CompensationHeart AttackCausationMedical TestimonyHypothetical QuestionExertionEmployment Death BenefitsArteriosclerotic Heart DiseaseAcute Myocardial InfarctionTennessee Law
References
4
Case No. MISSING
Regular Panel Decision

Banks v. St. Francis Hospital

The plaintiff, a central dispatch technician at St. Francis Hospital, suffered a severe chest pain on January 23, 1982, while lifting a heavy box, which aggravated a pre-existing 95% coronary artery stenosis. She underwent bypass surgery and was later deemed permanently and totally disabled. The trial court awarded benefits, which the employer appealed, arguing the action was time-barred and the award lacked evidence. The employer also objected to the trial judge's failure to rule on hypothetical questions. The Supreme Court affirmed the trial court's decision, finding the action was filed within the statute of limitations, the disability was supported by evidence, and the trial judge's handling of hypothetical questions did not constitute reversible error.

Worker's CompensationPermanent Total DisabilityTemporary Total DisabilityMedical ExpensesStatute of LimitationsPre-existing ConditionHeart DiseaseAggravation of InjuryBypass SurgeryHypothetical Questions
References
5
Case No. MISSING
Regular Panel Decision

Stafford v. Barnhart

Plaintiff Danny L. Stafford sought judicial review of the Commissioner of Social Security Administration's decision denying his application for a closed period of disability insurance benefits, marking his second federal court appearance for this claim. The court previously remanded the case for reconsideration of new evidence. Administrative Law Judge (ALJ) Harry L. Williams, Jr., reconsidered and again denied the application. Plaintiff alleged legal errors by the Commissioner in evaluating medical opinions and substantial evidence errors in credibility determinations and the hypothetical question posed to the vocational expert. The court, led by District Judge Heartfield, adopted the Magistrate Judge's report, finding no legal error in the ALJ's evaluation of the treating physician's opinion and concluding any other errors were harmless. The court also determined that the ALJ's credibility findings and the hypothetical question were supported by substantial evidence. Consequently, the Commissioner's decision was affirmed, and the plaintiff's action was dismissed.

Disability benefitsSocial Security ActALJ decision reviewTreating physician opinionMedical evidenceResidual functional capacityVocational expert testimonySubstantial evidenceHarmless errorChronic pain
References
26
Case No. MISSING
Regular Panel Decision
Mar 30, 1989

Davenport v. Taylor Feed Mill

Plaintiff, Douglas Wayne Davenport, an employee of Taylor Feed Mill, was injured on October 3, 1987, sustaining a ruptured lumbar disc and subsequently received a sixty percent occupational disability award from the Warren County Chancery Court. Defendant appealed the judgment on three grounds: the physician's anatomical impairment rating based on an old medical guideline edition, the vocational expert's testimony using a hypothetical question based on facts not fully in evidence, and the award of a lump sum payment. The Supreme Court affirmed the trial court's decision on the first two issues, concluding that the older guideline was permissible given the focus on vocational disability, and the hypothetical question's phrasing was within the trial court's discretion. However, the court reversed the lump sum payment award, as the plaintiff failed to demonstrate special needs or exceptional circumstances, remanding the case for accrued benefits to be paid according to the statutory periodic payment scheme.

Occupational DisabilityAnatomical ImpairmentVocational DisabilityLump Sum Payment ReversalMedical Guideline EditionExpert Witness TestimonyHypothetical Question ValidityPermanent Partial DisabilityTennessee Workers' CompensationBack Injury
References
10
Case No. MISSING
Regular Panel Decision
Jun 30, 1937

Cocke & Braden v. Ayer

The case concerns Ewell J. Ayer, who suffered personal injuries after being struck by a truck driven by Ed Foran. Ayer secured a judgment for $19,000 against Foran and his employers, Cocke & Braden. The Court of Civil Appeals, Seventh District, certified questions to the Commission of Appeals, Section A, primarily asking whether Foran was an independent contractor. The opinion details the contractual agreement and testimony regarding Cocke & Braden's control over Foran's work. After reviewing the facts and applicable precedents, the Commission of Appeals affirmed that Foran was, as a matter of law, an independent contractor. This decision rendered a second certified question immaterial.

Independent ContractorVicarious LiabilityTort LawCertified QuestionsTexas LawMaster-Servant RelationshipControl TestEmployment LawTrucking AccidentPersonal Injury
References
5
Case No. MISSING
Regular Panel Decision

Snyder v. LTG Lufttechnische GmbH

The Supreme Court of Tennessee addressed two certified questions from the United States District Court for the Eastern District of Tennessee concerning product liability actions. The central issue was whether defendants could present evidence of the plaintiff's employer's actions (alteration, improper maintenance, or abnormal use of the product) as contributing to the plaintiff's injuries, despite the employer's tort immunity under workers' compensation law. The Court affirmed that such evidence is admissible to establish cause-in-fact. However, the jury may not assess fault against the employer, ensuring the employer's immunity is maintained while allowing defendants to present a complete defense. The Court declined to reconsider its prior ruling in Ridings v. Ralph M. Parsons Co. and deemed the second certified question unnecessary to address.

Products LiabilityComparative FaultEmployer ImmunityWorkers' CompensationCause-in-FactProximate CauseStrict LiabilityNegligenceCertified QuestionsTennessee Law
References
8
Case No. MISSING
Regular Panel Decision

Carr v. United Parcel Service

The case addresses a certified question from the U.S. District Court for the Middle District of Tennessee concerning individual liability under the Tennessee Human Rights Act (THRA). Plaintiff Kelly Carr alleged sexual harassment against her employer, United Parcel Service (UPS), and three UPS employees. The individual defendants moved for judgment, arguing they could not be held individually liable. The Tennessee Supreme Court held that the THRA's 'agent of an employer' language does not impose individual liability, aligning with federal interpretations of Title VII. While the THRA provides for accomplice liability for individuals who aid, abet, incite, compel, or command an employer's discriminatory practice, the Court found no evidence under the certified facts to hold the non-supervisory and supervisory defendants individually liable for either co-worker harassment or supervisor-created hostile work environment, as their actions did not constitute aiding and abetting the employer's failure to take remedial action.

Sexual HarassmentTennessee Human Rights Act (THRA)Individual LiabilityEmployer LiabilityTitle VIICertified Question of LawRespondeat SuperiorAiding and AbettingHostile Work EnvironmentQuid Pro Quo Harassment
References
23
Case No. ADJ8424952
Regular
Sep 10, 2014

ALFONSO CRUZ vs. SIERRA CIRCUITS, INC.; THE HARTFORD

This case involves an applicant's petition for removal regarding deposition questions about medical history and insurance coverage. The Workers' Compensation Appeals Board (WCAB) granted the petition in part, allowing questions about medical insurance and personal doctors, as these are discoverable under CCP § 2017.010. However, the WCAB found questions about past medical treatment paid by others and prior hospitalizations to be overbroad, as they could infringe on the physician-patient privilege regarding unrelated conditions. The Board ordered the applicant to answer specific questions but requires defendants to reframe broader questions concerning medical history to avoid privileged information.

Petition for RemovalFifth AmendmentFirst Amendmentphysician-patient privilegeconfidential communicationindustrial injurymedical historydeposition questionsCode of Civil Procedure section 2017.010Evidence Code sections 990
References
3
Case No. MISSING
Regular Panel Decision

Jones v. Harris

Plaintiff Robert Jones, an incarcerated individual at Sing Sing, initiated this action alleging his cell was searched multiple times in retaliation for exercising First Amendment rights and in violation of his Eighth and Fourteenth Amendment rights, along with various property deprivations. Defendants, including correctional officers Harris and Allen, and Superintendent Marshall, moved to dismiss the complaint for failure to exhaust administrative remedies and to state a claim. The court granted dismissal of plaintiff's Eighth Amendment claims related to cell searches and alleged sexual harassment, as well as First Amendment retaliation claims concerning cell searches, property destruction, and false misconduct reports, citing insufficient factual allegations or failure to meet constitutional thresholds. However, the court denied dismissal of plaintiff's Fourteenth Amendment due process claim regarding the deprivation of three specific items of property against defendants Allen and Marshall, requesting further legal briefing on questions concerning the exhaustion of administrative remedies and access to post-deprivation procedures. Motions filed by the plaintiff for summary judgment and in limine were denied; the former as futile due to lack of exhaustion or constitutional violation, and the latter as premature.

Prisoner RightsFirst AmendmentEighth AmendmentFourteenth AmendmentDue ProcessRetaliationCell SearchProperty DeprivationQualified ImmunityAdministrative Remedies
References
45
Case No. ADJ6993381
Regular
Mar 12, 2013

RONALD GERTON vs. CITY OF PLEASANTON

The Workers' Compensation Appeals Board rescinded a prior award finding the applicant incurred a 62% permanent disability due to a low back injury. The Board remanded the case to develop the record on whether the applicant is amenable to vocational rehabilitation and its effect on his diminished future earning capacity. The Board also questioned the applicant's vocational expert's exclusion of actual post-injury earnings, which were substantial, in favor of hypothetical lower wage rates. This development is necessary to properly evaluate if the scheduled permanent disability rating has been rebutted.

Diminished Future Earning Capacity2005 Permanent Disability Rating Schedulevocational expertAgreed Medical Examinersubstantial evidencerebuttalapportionmentsheltered employmentLeBoeuf analysisopen labor market
References
10
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