The case of Jo Carol Edwards v. Peoplease, LLC, et al. is an important Tennessee workers’ compensation decision that clarifies when an aggravation of a pre-existing condition is compensable under the Workers’ Compensation Reform Act of 2013. Jo Carol Edwards, a truck driver for Peoplease, was injured in a work-related accident on August 14, 2020, when a tire blowout caused her truck to crash into a bridge. During the accident, her knees struck the underside of the dashboard. Although Ms. Edwards had severe, pre-existing arthritis in both knees, she testified that she had no knee pain or functional limitations before the accident and was able to fully perform her job. After the crash, however, she developed significant knee pain that ultimately led to total knee replacement surgery.
Cases like Edwards v. Peoplease highlight why guidance from a skilled Knoxville workers’ compensation attorney matters when insurers argue that an injury is merely a non-compensable aggravation of a pre-existing condition.
Ms. Edwards sought workers’ compensation benefits for her knee injuries. Multiple orthopedic physicians evaluated her, and their opinions conflicted. Some doctors, including her treating physician chosen from the employer’s panel, believed her arthritis predated the accident and that the crash merely exacerbated her symptoms in a way they considered non-compensable, largely because they believed Tennessee law required a permanent anatomical change. Other doctors concluded that the accident aggravated her previously asymptomatic arthritis, caused disabling pain, and was the primary reason she needed knee replacement surgery. The Court of Workers’ Compensation Claims found Ms. Edwards credible, noted her visible physical limitations in court, and determined that the work accident caused a compensable aggravation of her knee arthritis. The trial court awarded medical benefits, temporary disability benefits, and permanent total disability benefits.
Peoplease appealed, and the Workers’ Compensation Appeals Board reversed much of the trial court’s decision. The Appeals Board concluded that Ms. Edwards failed to overcome the statutory presumption favoring her treating physician’s causation opinion and determined that her knee replacement surgeries and resulting disability were not compensable because they would have been required regardless of the accident. A dissenting judge disagreed, finding that the evidence supported the trial court’s findings. Ms. Edwards then appealed to the Tennessee Supreme Court.
The Court clarified the meaning of an “aggravation” injury under the 2013 Reform Act. It held that an aggravation does not require a permanent anatomical change or permanent worsening of a condition to be compensable. Instead, an aggravation is compensable when an employee proves, to a reasonable degree of medical certainty, that the work accident contributed more than fifty percent to causing the aggravation and that the aggravation itself contributed more than fifty percent to the need for medical treatment or disability. The Court emphasized that the statute focuses on causation, not permanence.
Applying this standard, the Supreme Court concluded that the evidence supported the trial court’s ruling. The record showed that Ms. Edwards was asymptomatic before the accident, became symptomatic afterward, and only became eligible for knee replacement surgery due to the accident-related aggravation. The Court found that medical opinions requiring permanent anatomical change were legally flawed and entitled to less weight. As a result, the Court reversed the Appeals Board, reinstated the trial court’s December 12, 2023 order, and affirmed Ms. Edwards’ entitlement to medical and disability benefits, providing clear guidance on aggravation injuries and appellate review in Tennessee workers’ compensation law.
There is an important deviation from pre-2013 law here. It is now obvious that the injured worker does not have to prove an anatomical change to prove an aggravation of a preexisting condition. Evidence of an aggravation of a preexisting condition can include a loss of function where the condition was asymptomatic before or an increase in loss of function in an already symptomatic condition.
It is common for insurance companies to deny a workers’ compensation claim based upon an aggravation of a preexisting condition.
Contact one of our Knoxville personal injury attorneys today if that happens to you — call (865) 691-2777.