Case File
A Tennessee worker didn’t have history showing that her knee arthritis caused problems until a wreck on the job aggravated it. Did that make a difference for her workers’ compensation claim? Simply Research subscribers have access to the full text.
Case
Edwards v. Peoplease, LLC, No. W2024-01034-SC-R3-WC (Tenn. 12/22/25)
What Happened?
A worker was driving a truck for her employer when one of the tires blew out, sending the vehicle down an embankment and causing the worker to crash into a bridge. During the accident, the worker’s knees struck a panel underneath the dashboard.
The worker received treatment for her knee injuries, with one of the physicians opining that the worker had knee arthritis prior to the accident. The worker underwent a total left knee replacement and began discussions with her doctors about a right-knee replacement when she was denied coverage for both knee surgeries.
The worker filed a petition for expedited benefits determination with the Workers’ Compensation Claims Court.
The WCCC ordered the employer to reimburse the worker the cost of her left knee replacement, authorize the right knee replacement, pay past and ongoing temporary disability benefits, and reimburse her for mileage.
The employer appealed to the Workers’ Compensation Appeals Board, which reversed the WCCC’s order.
On remand, the WCCC determined that the worker proved by a preponderance of the evidence that the work accident aggravated her knee arthritis and ordered the employer to pay past medical bills related to the left knee replacement, current and future medical bills for the right knee, temporary disability benefits, permanent total disability benefits, and discretionary costs.
The employer appealed the order. The WCAB held that the knee surgeries and resulting disability were not compensable, prompting the worker to appeal to the Tennessee Supreme Court.
Rule of Law
Under Tennessee statutes, an “injury” does not include the aggravation of a preexisting disease, condition, or ailment unless it can be shown to a reasonable degree of medical certainty that the aggravation arose primarily out of an in the course and scope of employment.
Workers’ Comp 101: In Tennessee, “shown to a reasonable degree of medical certainty” means that, in the opinion of the physician, it is more likely than not considering all causes, as opposed to speculation or possibility.
An injury arises primarily out of and in the course and scope of employment only if it has been shown by a preponderance of the evidence that the employment contributed more than 50% in causing the injury, considering all causes.
What the Tennessee Supreme Court Said
The Tennessee Supreme Court reasoned that an aggravation injury could cause the need for medical treatment without resulting in an anatomical change or permanent worsening of the condition, as in the case of an injury that arose out of the course and scope of employment that ultimately resolved through medical treatment, and held: 1) the truck accident contributed more than 50% in causing the aggravation of the worker’s preexisting arthritis; and 2) the aggravation of the worker’s preexisting arthritis contributed more than 50% in causing the need for her knee surgeries.
Although there was disagreement among the medical professionals in the case, the Tennessee Supreme Court agreed with the WCCC’s analysis that the worker was never diagnosed with arthritis before the accident and that her medical and work history provided no indication that she struggled with knee issues prior to the work accident.
“Put simply, [the worker] only became eligible for knee-replacement surgery once she became symptomatic after the accident aggravated her preexisting arthritis,” the court wrote. “In this way, the evidence below shows, to a reasonable degree of medical certainty, that the aggravation caused the need for knee replacement surgery.”
Thus, the court upheld the worker’s claim for temporary and permanent total disability benefits.
Verdict: The Tennessee Supreme Court reinstated the WCCC’s determination in the case.
Takeaway
In Tennessee, an “aggravation” injury does not require proof of a permanent change or a permanent worsening of conditions to be compensable. Instead, an aggravation injury is compensable when an employee shows, to a reasonable degree of medical certainty, that the aggravation injury primarily arose out of and in the course and scope of the employment.
This means that an employee must show that the employment contributed more than 50% in causing the aggravation and then the employee must prove by a reasonable degree of medical certainty that the aggravation contributed more than 50% in causing death, disablement, or need for medical treatment.
