Erica Lee v. Amazon

Summary

The Tennessee Workers’ Compensation Appeals Board affirmed an interlocutory order denying Erica Lee additional medical and temporary disability benefits arising from a shoulder injury allegedly sustained while working for Amazon. The Board concluded that the authorized treating physician’s causation and medical-necessity opinions retained a presumption of correctness and were not rebutted by an unauthorized physician’s opinion based on a later MRI. The Board also declined to find the appeal frivolous and remanded the case.

Holdings

1. The trial court properly denied additional medical benefits because the authorized treating physician's opinions regarding causation and medical necessity were presumed correct, and the conflicting opinion from the unauthorized physician was insufficient to rebut that presumption.
2. Lee was not entitled to temporary total disability benefits at this stage because she failed to establish that the work injury primarily caused her current condition and failed to establish the duration of the period of disability.
3. The appeal was not frivolous because it was not devoid of merit or brought solely for delay, particularly given the conflicting medical opinions regarding the primary cause of Lee's shoulder condition.

Questions Presented

1. Whether the trial court properly denied additional medical benefits because the authorized treating physician's opinion on causation and medical necessity was presumed correct and was not rebutted by the unauthorized physician's opinion.
2. Whether Lee established entitlement to temporary total disability benefits, including causation and the duration of the claimed disability period.
3. Whether the appeal was frivolous.

Disposition

affirmed