Introduction
Spicer Rudstrom, PLLC partner Jared Renfroe successfully secured a favorable outcome for his client, resulting in the dismissal of a workers’ compensation claim before the Tennessee Court of Workers’ Compensation Claims. The case, Dwaine Coleman v. W.K. Kellogg Co., involved a disputed mental injury claim.
The claimant, Mr. Coleman, alleged that his job duties as a maintenance worker caused him to sustain a mental injury. However, after a thorough investigation conducted by Jared and the employer, it was determined that the claim did not meet the legal requirements under Tennessee workers’ compensation laws for a compensable mental injury.
When Mr. Coleman challenged the denial, the case advanced to an Expedited Hearing. Both sides presented evidence and arguments during the proceedings. After reviewing the case, the Court issued an Order Denying Benefits, siding with the employer and insurance carrier.
Why the Court Ruled Against the Claim
Jared successfully demonstrated that the alleged mental injury failed to satisfy the statutory requirements for a compensable mental injury under Tennessee law. The Court affirmed that to qualify as a compensable mental injury, the injury must:
• Arise primarily from a specific, identifiable work-related event.
• Be caused by a sudden or unusual stimulus.
Additionally, the Court emphasized that workers’ compensation does not cover all stress or undesirable experiences encountered in the workplace. For a claim to succeed, the alleged event must be extraordinary when compared to the ordinary stress experienced by others performing similar duties.
The Court found that Mr. Coleman’s subjective perception of the event was insufficient as a basis for compensation. Because the same stimulus may not have been extraordinary for other employees in the same position, the claim did not meet the required legal threshold. Following this decision, Mr. Coleman did not appeal the ruling, and after a subsequent status hearing, the claim was dismissed.
Analysis
Reflecting on the case, Jared stated, “The case involved a genuine dispute that was presented well, but ultimately the court made the right decision consistent with the law.”
Contact Info
Jared Renfroe works out of the firm’s Memphis and Little Rock offices. His practice focuses on defending employers and insurance carriers in complex workers’ compensation claims across Tennessee, Arkansas, and Mississippi. To connect with Jared for questions, feel free to reach out at [email protected] or (901) 522-2317.
Spicer Rudstrom, PLLC (SR) is a mid-size law firm serving clients with legal and business needs. With offices in Nashville, Memphis, Chattanooga, Knoxville, and Little Rock, Arkansas, SR represents clients in every county in Tennessee, Arkansas, as well as northern Mississippi, north Georgia and southern Kentucky. Clients include local, regional and national companies and individuals. SR has represented many of its clients for decades, some for more than 40 years.