Baugus, Alice v. Tennessee Farmers Mutual Insurance Company
The employee, Alice Baugus, sought to set aside an order approving the settlement of her workers' compensation claim, arguing she lacked the emotional or mental capacity to enter the agreement due to severe stress, anxiety, and medication. The trial court, Dale A. Tipps, denied her motion, concluding she failed to provide grounds for relief by clear and convincing evidence under Rule 60.02 of the Tennessee Rules of Civil Procedure. On appeal, the Tennessee Workers' Compensation Appeals Board affirmed the trial court's decision. The Board emphasized that relief under Rule 60.02 is a rare and disfavored "exceptional remedy" for "extreme, unique, exceptional, or extraordinary cases" and is not intended for situations where circumstances change or a party is merely dissatisfied with an outcome, unless clear and convincing evidence of a Rule 60.02 condition is presented. The Appeals Board found the employee did not meet this burden.