Nelson v. Wal-Mart Stores, Inc.
The Tennessee Supreme Court reviewed a workers' compensation case involving Betty Nelson, who sustained a broken hip while working for Wal-Mart, resulting in an 8% medical impairment to the body as a whole. The primary issues were whether there was a "meaningful return to work" under Tenn. Code Ann. § 50-6-241 and the applicability of Tenn. Code Ann. § 50-6-242 to lift statutory disability caps. The Court affirmed the Special Workers’ Compensation Appeals Panel’s finding that there was no "meaningful return to work" because Wal-Mart's job offers were not reasonable given Nelson's physical limitations and lack of accommodation. Consequently, Tenn. Code Ann. § 50-6-241(b) applied, allowing for a higher maximum disability award. The Court also affirmed that Tenn. Code Ann. § 50-6-242 applied due to Nelson's age, lack of education, and job skills, permitting the award to exceed the statutory cap. The Court upheld the trial court's award of 60% permanent partial disability, modifying the Panel's judgment regarding the specific statutory sections.