Darlene Taylor as Surviving Spouse of Darrell Taylor v. Dale’s Recycling

Summary

The Tennessee Court of Workers’ Compensation Claims held that Darlene Taylor was entitled to survivor benefits after her husband, Darrell Taylor, suffered a fatal heart attack while performing work-related tasks. The court found that physical exertion, emotional stress from an unexpected traffic stop, and heat exposure primarily caused the heart attack despite preexisting medical conditions. The court awarded death benefits totaling $504,450, burial expenses, attorney’s fees, and discretionary costs.

Holdings

1. The claimant proved by a preponderance of the evidence and to a reasonable degree of medical certainty that Taylor’s fatal heart attack arose primarily out of his employment because the work-related physical exertion, sudden emotional stress, and heat contributed more than 50 percent to the death.
2. The statute in effect on the date of injury governs the parties’ workers’ compensation rights; consequently, the court applied the version of Tennessee Code Annotated section 50-6-210 in effect on June 22, 2023.
3. The claimant and eligible stepson were entitled to the stipulated death-benefit award of $504,450, burial expenses of $8,667.81, attorney’s fees of $100,890, and discretionary costs of $4,436.10.

Questions Presented

1. Whether Taylor’s fatal heart attack arose primarily out of and in the course of his employment under Tennessee’s post-Reform Act workers’ compensation law.
2. Whether the claimant was entitled to stipulated death benefits, burial expenses, attorney’s fees, and discretionary costs after proving compensability.

Disposition

other