Corum v. Holston Health & Rehabilitation Center
This Supreme Court opinion addresses whether the failure to file a statistical data (SD1) form contemporaneously with a final judgment in a workers' compensation case affects the judgment's finality for appeal purposes. The employer, Holston Health Care and Rehabilitation Center, appealed an adverse workers' compensation ruling, arguing the appeal time hadn't begun due to the missing SD1 form. The employee, Linda J. Corum, contended the appeal was untimely under Rule 4 of the Tennessee Rules of Appellate Procedure. The Court held that the Supreme Court's procedural rules supersede conflicting statutes, ruling that a workers' compensation judgment is final on the date of entry by the trial court clerk, regardless of the SD1 form's filing. Consequently, the employer's appeal was dismissed as untimely.