Primm, Chad v. Central Sales & Service, Inc.

Summary

The Tennessee Court of Workers’ Compensation Claims awarded Chad Primm permanent partial disability benefits based on a 7% impairment rating following a work-related low-back injury. The court denied permanent total disability benefits, dismissed the Subsequent Injury and Vocational Recovery Fund, and awarded past temporary disability benefits, future medical benefits, attorney fees, and discretionary costs. The compensation order was entered on June 24, 2026.

Holdings

1. Primm failed to prove by a preponderance of the evidence that he was unable to work at any occupation that would produce income; therefore, he was not permanently and totally disabled.
2. Central Sales rebutted the presumption favoring the authorized physician's 12% impairment rating, and Primm was entitled to an original award based on a 7% medical impairment.
3. A physician assistant acting under the supervision of a licensed physician may impose work restrictions; the applicable regulation does not reserve that function exclusively to a supervising physician.
4. Primm was entitled to temporary partial disability benefits from February 22 through September 3 because Central Sales failed to prove that misconduct under established or ordinary workplace rules, rather than the work injury, was the true motivation for his termination.
5. The Fund had no liability because Primm was not permanently and totally disabled and the required statutory conditions were not established.

Questions Presented

1. Whether Primm was permanently and totally disabled under Tennessee workers' compensation law.
2. Whether the 12% impairment rating assigned by the authorized physician was rebutted by the competing 7% rating.
3. Whether Primm was entitled to temporary partial disability benefits after his termination.
4. Whether the Subsequent Injury and Vocational Recovery Fund had liability.
5. What future medical benefits, attorney fees, filing fees, and discretionary costs should be awarded.

Disposition

other