Rowe, Tina v. Mitsubishi Motors North America, Inc.
The Tennessee Workers' Compensation Appeals Board affirmed the trial court's denial of the employer's motion for summary judgment. Employee Tina Rowe sustained injuries from a fall in a parking lot while on her way to retrieve a work-related headset from her car. The employer, Mitsubishi Motors North America, Inc., sought summary judgment, arguing the accident did not arise from or within the course and scope of employment. However, the Board found genuine issues of material fact regarding the accident's cause and its connection to employment. The decision also clarified that the "parking lot" rule from Lollar v. Wal-Mart Stores, Inc. remains applicable, rejecting the employer's assertion that it was no longer good law after the 2013 Workers' Compensation Reform Act. The case was remanded for further proceedings.