Bryant v. Genco Stamping & Mfg. Co., Inc.
Bernard Bruce Bryant, a 46-year-old machinist, suffered from pre-existing panic disorder, agoraphobia, and major depressive disorder, as well as blindness in his right eye. In 1996, while employed by Genco, he sustained a work-related shoulder injury. Treatment for this injury, specifically anesthesia during surgery, severely aggravated his pre-existing mental conditions, rendering him permanently and totally disabled. The trial court initially found Genco and the Second Injury Fund liable, apportioning benefits. However, the Special Workers’ Compensation Appeals Panel reversed the Second Injury Fund's liability, holding that Tennessee Code Annotated section 50-6-208(a), which concerns "permanent physical disability," does not apply to pre-existing mental disorders. The Tennessee Supreme Court affirmed the Panel's decision, ruling that section 50-6-208(a) applies only to physical disabilities, thereby holding Genco fully liable for Mr. Bryant's permanent total disability benefits, which included both his physical and aggravated mental disabilities.