Linda S. Reece v. Findlay Industries, Inc.; Harold Edward Tigue, Jr. v. Tokio Marine & Fire Insurance Company, et al.

Summary

The Tennessee Supreme Court consolidated two workers’ compensation appeals involving Linda S. Reece and Harold Edward Tigue. The court held that the trial judge improperly delegated adjudication of the cases to the chancery clerk and master, including reliance on proposed judgments that did not reflect the judge’s own findings. The judgments were reversed and the cases remanded for new trials.

Holdings

1. A trial judge may not delegate the adjudication of the main issues in workers' compensation cases to a clerk and master who did not preside over the trial or hear the witnesses. The trial judge must personally perform the judicial duties required by law, subject only to the limited circumstances permitting appointment of a special judge.
2. Because the trial court improperly delegated adjudication of the cases, the judgments must be reversed and the cases remanded to the trial court for new trials.

Questions Presented

1. Whether the trial judge improperly delegated the adjudication of the consolidated workers' compensation cases to the clerk and master.
2. Whether the trial court judgments should be reversed and the cases remanded for new trials because the trial judge did not personally perform the duties required of the judicial office.

Disposition

reversed_and_remanded