Figueroa v. Amazon.com, Inc., et al.

Summary

The Tennessee Workers’ Compensation Appeals Board affirmed and remanded an order staying an expedited workers’ compensation award of temporary disability and medical benefits. The Board held that the employee did not preserve her challenge to the stay because the parties agreed to obtain a causation opinion from the authorized treating physician and she did not object to that procedure in the trial court.

Holdings

1. An expedited hearing order is interlocutory, not final, and remains subject to amendment, reversal, or revision before entry of a final compensation order.
2. Figueroa did not preserve her challenge to the stay because she agreed to the process discussed at the status hearing, did not object that the agreement would suspend benefits, and did not move for reconsideration after the order was entered.
3. The trial court properly entered the stay order, and the order is affirmed.

Questions Presented

1. Whether the trial court abused its discretion or otherwise erred by staying its prior expedited-hearing order awarding temporary total disability and medical benefits.
2. Whether Figueroa preserved for appellate review her challenge to the stay when she agreed at the status hearing to the process that resulted in the stay and did not object or seek reconsideration in the trial court.
3. Whether an expedited workers' compensation hearing order is subject to amendment, reversal, or revision before entry of a final compensation order.

Disposition

affirmed