Underwood v. Zurich Insurance Co.
Cas Underwood, an employee of BASF Corporation, sustained work-connected injuries from an explosion. He received a lump-sum disability award, which was later paid by Zurich Insurance Company. Subsequently, Underwood was diagnosed with Post-traumatic Stress Disorder (PTSD) and petitioned to reopen the final judgment, seeking additional disability benefits. The trial court dismissed his petition to reopen, citing a Tennessee statute on the finality of lump-sum payments, but granted his motion for future medical expenses related to PTSD. On appeal, the Supreme Court of Tennessee affirmed the trial court's decision, concluding that an increase in disability after a lump-sum award does not constitute grounds for relief under Tenn.R.Civ.P. 60.02(5) and that timely notice was given for medical expenses.