By Courtney S. Paterson

In an effort to help our clients stay informed on legal issues affecting their business, Spicer Rudstrom’s attorneys strive to make sense of the complex challenges and recent legal developments in the ever-changing world of workers’ compensation law. Our attorneys summarize the cases handed down in the Tennessee Workers’ Compensation Appeals Board each week, providing insight on the recent legislation as a resource to employers across industries, as well as insurance providers and carriers.

Dwight Mitchell v. Randstad North America, et al. 

Docket No. 2015-06-0954
State File No. 88416-2015
Filed August 2016

Posture: This is a case before the Appeals Board on an interlocutory appeal filed by the employee, and the dispute was whether the employer should be required to provide medical benefits.

This appeal involves an employee who reached a settlement for work-related injuries suffered by the employee on April 9, 2014. The settlement, which closed the employee’s right to future medical treatment, included language describing two alleged aggravating events occurring after July 1, 2014.

The court’s order approving the settlement noted that this payment was for “full, final and complete settlement and discharge of [Employer] and its insurer from any further liability to [Employee] for any claimed medical condition or disability . . . by reason of said alleged accident or aggravations.” (Emphasis added.) The agreement was approved by the Davidson County Circuit Court. Subsequently, the employee filed petitions for benefits determination, seeking additional benefits for injuries that were identified as aggravations in the settlement documents. The trial court denied benefits based on the parties’ prior court-approved settlement.

The Appeals Board affirmed the trial court’s decision. The trial observed that “[b]y the plain language of the agreement, which he testified he read, reviewed, signed and understood at the time,’ [Employee] expressly acknowledged aggravations of a prior work-related injury on September 23, 2014, and March 12, 2015.” In denying relief, the trial court also noted that Employee accepted a lump-sum payment as a “full, final and complete settlement and discharge of [Employer] from any further liability . . . by reason of said alleged accident or aggravations.”


An associate with Spicer Rudstrom since 2009, Courtney focuses her practice on automobile liability, insurance coverage litigation, insurance defense litigation, insurance subrogation, premises liability, products liability, and workers’ compensation. She is admitted to practice in all trial and appellate state courts in Tennessee, as well as the U.S. District Court for the Middle District of Tennessee.


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