Love, Emilie v. Love Management, Inc.
An employee, Emilie Love, suffered severe injuries in an accident while placing luggage in a car. Her workers' compensation insurer, Zenith Insurance Company, denied the claim, asserting the injuries did not occur in the course and scope of employment. The trial court granted Love's motion for partial summary judgment, ruling that her injuries occurred within the course and scope of her employment. Zenith appealed this decision, arguing errors in procedural and substantive rulings. The Tennessee Workers' Compensation Appeals Board reversed the trial court's order, finding an abuse of discretion in denying Zenith's motion to continue and the application of an incorrect legal standard for summary judgment. The case was remanded for further proceedings consistent with the Appeals Board's opinion.