Summary
This Tennessee Workers' Compensation Appeals Board decision reverses a trial court's grant of summary judgment in a workers' compensation mental injury claim. The board concluded that genuine issues of material fact existed regarding whether the circumstances of the employee's performance review constituted a sudden or unusual mental stimulus beyond ordinary workplace stress. Accordingly, the case was reversed and remanded for further proceedings.
Topics
Practice areas
Questions Presented
- Whether the trial court erred in granting summary judgment on the employee’s mental‑injury claim under Tennessee Workers’ Compensation Law.
- Whether the alleged workplace events constitute a “sudden or unusual” mental stimulus beyond normal workplace stress.
- Whether the trial court correctly applied the objective “reasonable person” standard to the employee’s alleged stress.
Holdings
- The Appeals Board reverses and remands, holding that summary judgment was improper because genuine issues of material fact exist as to whether the February 28 events constitute a sudden or unusual mental stimulus.
Key quotations
“The trial court concluded that Employee had produced insufficient evidence of “a sudden or unusual mental stimulus for an ordinary employee” and dismissed Employee’s claim with prejudice.”
“We conclude a critical element in mental injury cases involves application of a “reasonable person” standard, which is generally a question of fact.”
“Summary judgment is inappropriate if granting the motion would involve fact‑finding or the weighing of evidence.”
Factual background
Employee Julie Lawson, a business analyst, alleged sexual harassment by her supervisor and claimed that a February 28, 2023 virtual meeting in which the word “kidnapped” was used, followed by a performance review conducted by male supervisors aware of her harassment allegations, caused a sudden and unusual mental stimulus that aggravated her pre‑existing PTSD.
Procedural history
Employee filed a workers' compensation claim for a mental injury. The trial court granted summary judgment in favor of the employer and dismissed the claim. Employee appealed to the Workers' Compensation Appeals Board.
Remand instructions
The case is remanded to the Court of Workers’ Compensation Claims for further proceedings consistent with this opinion.