Gillum, Mary v. Dollar General Corporation
The Tennessee Workers' Compensation Appeals Board affirmed and remanded a trial court's decision concerning an employee, Mary Gillum, who alleged neck and shoulder injuries from a falling dog food bag at work. Following an expedited hearing, the trial court found the authorized treating physician's opinion sufficient to establish that Ms. Gillum would likely prevail on the merits. The court ordered Dollar General Corporation to provide a panel of physiatrists for nonoperative treatment and awarded temporary disability benefits. Dollar General appealed, arguing insufficient evidence of an injury arising primarily out of employment and that the physician's report did not meet the 50% causation requirement. The Appeals Board, however, found no merit in the employer's arguments, clarifying that a 'lesser evidentiary standard' applies at expedited hearings compared to a hearing on the merits.