Tennessee Supreme Court Clarifies Workers’ Comp Standard for Pre-Existing Conditions

In a significant ruling for Tennessee employers and workers’ compensation insurers, the state’s Supreme Court has clarified the standard for compensability when a work-related accident aggravates an employee’s pre-existing condition.

In Jo Carol Edwards vs. Peoplease LLC, the court reversed a lower board’s decision, finding that an employee’s injury does not need to cause a permanent worsening of their condition to be covered. The decision establishes a clearer causation framework that will guide how insurers evaluate and manage claims involving underlying health issues.

The case originated from an August 2020 incident when Jo Carol Edwards, a truck driver for Peoplease, crashed her vehicle after a tire blowout, injuring her knees. While Edwards had severe, pre-existing arthritis in both knees, she testified that she had been asymptomatic and fully capable of performing her duties prior to the accident.

The crash, however, caused significant pain and led to a diagnosis that included a knee fracture. Her doctors ultimately recommended total knee replacements for both knees. Peoplease’s workers’ compensation carrier denied coverage for the surgeries, contending that they were necessitated by her underlying arthritis, not the work accident.

Edwards argued that the accident was the direct cause of her need for medical treatment and subsequent disability. Her claim was supported by medical experts who testified that the accident aggravated her previously painless condition, making it symptomatic and creating the need for surgery.

Peoplease countered that the accident only caused a temporary exacerbation of her symptoms. Its medical experts argued that a compensable “aggravation” required a permanent anatomical change to the knee, which they claimed had not occurred. They asserted that her severe arthritis was the primary driver for the knee replacements, regardless of the accident.

The Supreme Court’s analysis focused on defining an “aggravation injury” under the state’s 2013 Workers’ Compensation Reform Act. The court rejected the defense’s narrow interpretation, stating that the plain meaning of “aggravation” does not require a permanent change.

The court held that an aggravation is compensable if a two-part causation test is met. First, the employee must show the work accident contributed more than 50% to causing the aggravation. Second, they must prove the aggravation itself contributed more than 50% to the need for medical treatment or disability. “Simply put,” the court wrote, “aggravation means an intensification or worsening of a preexisting disease, condition or ailment, permanent or not, that contributes more than fifty percent in causing death, disability or the need for medical treatment.”

Ultimately, the court concluded that Ms. Edwards had met this standard. It was undisputed that the accident caused her asymptomatic arthritis to become painfully symptomatic. Because knee replacement surgery is not performed on asymptomatic patients, the court found that the accident-induced aggravation was the primary cause of her need for the procedures. The court reinstated the trial court’s original award, holding Peoplease responsible for Ms. Edwards’ knee surgeries and related temporary and permanent total disability benefits.

View the full decision here. &