Kristina Andrew v. Accu Reference Medical and Technology Insurance Company

Summary

The Tennessee Court of Workers’ Compensation Claims denied Kristina Andrew’s request for workers’ compensation benefits after an expedited hearing concerning injuries allegedly sustained in a workplace altercation. The court held that Andrew was unlikely to prove she provided timely and sufficient notice of her injury because her communications did not reasonably convey that she had been injured, and the employer lacked actual knowledge of the injury. The court set a status conference for June 22, 2026, and included instructions for appealing the expedited order.

Holdings

1. The employer did not have actual knowledge of Andrew's injury because her communications described an altercation but did not reasonably convey that she had suffered an employment-related injury.
2. Andrew did not provide the written notice required by Tennessee law because she did not notify the employer of the nature and cause of an injury within 15 days of the accident.

Questions Presented

1. Whether Andrew was likely to prove that she provided timely written notice of her work-related injury within 15 days as required by Tennessee law.
2. Whether the employer had actual knowledge of the time, place, nature, and cause of the injury sufficient to excuse the statutory written-notice requirement.
3. Whether Andrew's communications to Jamison and her direct supervisor reasonably conveyed that she had suffered an injury arising out of and in the course of employment.

Disposition

other