Burkes, Jerry v. Sysco Knoxville, LLC
The employee, Jerry R. Burkes, appealed the trial court's denial of extraordinary benefits after sustaining a compensable knee injury while working for Sysco Knoxville, LLC. Although the trial court awarded increased general benefits, it denied the extraordinary benefits because Burkes failed to submit a Physician Certification Form, a statutory requirement. On appeal, the Tennessee Workers' Compensation Appeals Board affirmed the trial court's decision, emphasizing that strict compliance with statutory mandates for extraordinary benefits, particularly the Physician Certification Form, is necessary and substantial compliance is insufficient. The Board concluded that the absence of the required form was fatal to the employee's claim for extraordinary benefits. Consequently, the trial court's denial of extraordinary benefits was affirmed, and the order was certified as final.