Harman v. Moore's Quality Snack Foods, Inc.
Kimberly Dawn Harman and her husband sued Moore’s Quality Snack Foods, Inc., alleging sexual harassment and discrimination in violation of the Tennessee Human Rights Act (THRA) and Federal Civil Rights Acts, also claiming outrageous conduct and intentional infliction of emotional distress. The defendant sought summary judgment, arguing the claims were barred by the exclusive remedy provision of the Tennessee Worker’s Compensation Act (TWCA). The chancellor initially found an implied repeal of the TWCA's exclusive remedy concerning THRA claims. On appeal, the court affirmed the outcome that the plaintiffs' claims under the THRA were not barred but rejected the chancellor's reasoning of implied repeal. The appellate court distinguished the purposes of the two acts, holding that THRA claims for non-physical injuries like humiliation and emotional distress are separate from physical injuries covered by TWCA, and thus, not barred by its exclusive remedy.