Lively, Jason v. Prudential Security, Inc.
Jason Allen Lively, a security officer, injured his shoulder while restraining a combative patient. Prudential Security, Inc. accepted the shoulder claim, and Mr. Lively was treated by Dr. Jon MacNaughton. Subsequently, Mr. Lively obtained independent medical evaluations from Dr. C.M. Salekin and Dr. William Kennedy, both of whom suggested he suffered from depression/anxiety related to the chronic pain from his work injury and recommended a psychological evaluation. However, Dr. MacNaughton, the authorized treating physician, never referred Mr. Lively for a psychological evaluation and his notes did not reflect psychological symptoms. The Court, interpreting Tennessee Code Annotated section 50-6-204(h), ruled that psychological services require a referral from an authorized treating physician. Consequently, Mr. Lively's request for a psychological evaluation was denied.