Williams, Ashton v. Performance Food Group, Inc.

Summary

The Tennessee Court of Workers’ Compensation Claims granted Ashton Williams’s request for medical benefits after finding that he was likely to prove he sustained a work-related right shoulder injury. The court ordered Performance Food Group, Inc. and its carrier to schedule an authorized medical appointment and provide reasonable and necessary treatment, while denying payment for unauthorized treatment at that time. The case was referred to the Compliance Program for possible penalties, and a status hearing was set.

Holdings

1. Williams established a likelihood of proving at a merits hearing that he suffered an injury by accident arising primarily out of and in the course and scope of his employment and therefore was entitled to medical benefits.
2. An injured worker is not required to establish medical causation as a prerequisite to an employer's furnishing medical treatment under the workers' compensation statute.
3. Performance Food Group and its carrier must return Williams to the authorized physician and furnish reasonable and necessary medical treatment made necessary by the alleged work injury.
4. The court denied Williams's request for payment of unauthorized medical bills at that time because no physician had yet provided a causation opinion.

Questions Presented

1. Whether Williams demonstrated a likelihood of proving that he sustained an injury by accident arising primarily out of and in the course and scope of employment.
2. Whether an injured worker must present expert medical causation evidence before an employer is required to furnish medical treatment.
3. Whether the employer and carrier must provide authorized medical benefits and pay for treatment obtained without authorization.

Disposition

other