Eason, Adrianne v. Federal Express Corporation

Summary

The Tennessee Court of Workers’ Compensation Claims denied Adrianne Eason’s request for medical benefits related to a left-knee mass arising after a 2023 workplace injury. The court held that her petition was untimely under Tennessee Code Annotated § 50-6-203 because it was filed more than one year after the employer’s last voluntary benefit payment and that no applicable exception had been shown.

Holdings

1. The petition was untimely because it was filed more than one year after the later of the last authorized treatment date and the date Federal Express ceased making compensation payments.
2. The relevant date is the date the employer issued the last payment of compensation, not the date the employee or provider received or cleared it.
3. Eason's date of requesting medical treatment was immaterial because the statute requires the filing of a petition, and she did not present an applicable exception to the limitations defense.

Questions Presented

1. Whether Eason's petition was barred by Tennessee Code Annotated section 50-6-203(b)(2) because it was filed more than one year after the later of the last authorized treatment date or the date the employer ceased paying compensation.
2. Whether the limitations period runs from the date the employer issued its last payment or from the date the payment was received or cleared.
3. Whether any applicable exception to the statute of limitations prevented dismissal or denial of benefits.

Disposition

other