Summary
The Tennessee Workers' Compensation Appeals Board reviewed whether the trial court abused its discretion by refusing to hear the employer's dispositive motion until after an expedited hearing. The Board concluded that trial courts possess broad discretion to manage their dockets and schedule hearings, finding no violation of procedural due process or governing regulations. Accordingly, the Board affirmed the trial court's order and remanded the case.
Topics
Practice areas
Questions Presented
- Whether the trial court abused its discretion by refusing to hear the employer’s dispositive motion until after an expedited hearing
- Whether the trial court’s order violated the employer’s procedural due‑process rights under the Fourteenth Amendment
Holdings
- The trial court did not abuse its discretion; its decision to schedule the dispositive‑motion hearing after the expedited hearing is affirmed.
- The trial court’s order does not constitute a procedural due‑process violation.
Key quotations
“We find nothing in this record suggesting that Employer was prohibited from filing a dispositive motion. Tenn. Comp. R. and Regs. 0800-02-21-.18(1) specifies that a dispositive motion may be filed “in accordance with the Tennessee Rules of Civil Procedure.”” (at *26)
“We conclude Employer “has offered no evidence or argument that the trial court’s process in conducting hearings, selecting trial dates, and/or controlling the pace of litigation is arbitrary or otherwise runs afoul of those constitutional protections.”” (at *8)
Factual background
Joseph Farmer injured his low back and left wrist on December 4, 2023 while working for Five Star Building Group. The employer initially accepted the claim, provided treating physicians, and later filed a petition for an employer’s examination. After a series of hearings, the trial court issued a scheduling order stating the employer could file a dispositive motion but it would not be heard until after an expedited hearing scheduled for July 16, 2025.
Procedural history
Employer appealed the trial court’s order refusing to hear its dispositive motion until after an expedited hearing, arguing abuse of discretion and a procedural due‑process violation. The Board reviewed the record and affirmed the trial court’s discretion, remanding for further proceedings.
Remand instructions
Remand the case for further proceedings consistent with this opinion.