Mitch Burkhart and Christine Burkhart v. Sedgwick Claim Management Services, Inc. and Concentra Integrated Services, and rgv/nueces Rehabilitation D/B/A Innovative Physical and Occupational Therapy
Mitch Burkhart sustained a foot and ankle injury while training for his employer, Verizon Communications. Verizon's workers' compensation claims were administered by Sedgwick Claim Management Services, Inc., who, along with Concentra Integrated Services, arranged a Functional Capacity Evaluation (FCE) for Burkhart with RGV/Nueces Rehabilitation d/b/a Innovative Physical and Occupational Therapy. The Burkharts alleged that the FCE aggravated Mitch's injury, causing permanent damage. They sued Sedgwick, Concentra, and Innovative, claiming negligence, civil conspiracy, assault, fraud, and breach of the duty of good faith and fair dealing. The trial court dismissed the case against Innovative for an inadequate expert report and granted summary judgment to Sedgwick and Concentra, citing the exclusive remedy provision of the Texas Workers' Compensation Act. The appellate court affirmed the trial court's judgment, concluding that Mitch's aggravation injury was an 'extension injury' covered by the exclusive remedy provision of the TWCA.