Davidson v. Lewis Bros. Bakery
Charles Wayne Davidson injured his shoulder in 2001 while working for Lewis Brothers Bakery and filed a workers' compensation claim, also naming the Second Injury Fund. After a voluntary non-suit in 2004, Davidson refiled the claim later that year, after the one-year statute of limitations had run. The Fund argued that the "savings statute" (Tennessee Code Annotated section 28-1-105(a)) did not apply to claims against it due to sovereign immunity. The Supreme Court of Tennessee agreed, holding that the savings statute does not waive the Fund's sovereign immunity and thus does not "save" claims against it after the statute of limitations has expired. The court modified the trial court's order, dismissing the Second Injury Fund and removing its liability for benefits and costs.