The Tennessee Workers’ Compensation Appeals Board decision is important because it upheld a trial court decision that an injured worker has a right to privacy over his banking information and may protect himself from having to turn over his bank statements.
In the case Robert Anderson v. U.S. Foods, Inc., et al., the Tennessee Workers’ Compensation Appeals Board reviewed an interlocutory appeal stemming from a discovery dispute in a workers’ compensation claim. Robert Anderson, the employee, alleged he sustained a back injury on June 15, 2022, while making deliveries for U.S. Foods.
Although the employer initially accepted the claim, it later denied further benefits, asserting that Anderson had sustained a subsequent back injury in a 2023 car accident and received a monetary settlement for it. U.S. Foods argued that this new injury severed its responsibility for the original 2022 injury and sought reimbursement or credit for any temporary disability benefits it had paid.
In response to Anderson’s petition for benefit determination, the employer filed multiple discovery motions. Specifically, U.S. Foods sought access to personal and financial information, including details about Anderson’s children, child support obligations, banking accounts and statements, sources of income, tax returns, and pay stubs.
The employer argued this information was necessary to determine whether Anderson had other income sources or financial obligations, such as child support, that could affect the calculation or garnishment of workers’ compensation benefits. Anderson objected to the majority of these requests, asserting that they were irrelevant, overly broad, and constituted an undue intrusion into his personal life.
The trial court granted the employer’s motion in part. It ordered Anderson to produce his W-2s, tax returns, and pay stubs, and to disclose whether he had any child support obligations. However, the court denied the motion as it pertained to detailed personal information about Anderson’s children and his banking records, including the names of his banks and account statements.
The court applied a balancing test, weighing the employer’s need for information against the potential harm or privacy concerns associated with disclosing such data. It concluded that the requested financial and familial information was too invasive and not sufficiently justified by the employer’s stated needs, especially considering the employer already had access to tax and wage documents showing income sources.
U.S. Foods appealed, arguing the trial court abused its discretion by denying access to Anderson’s bank information and children’s details. It claimed there is no reasonable expectation of privacy in banking records, as individuals voluntarily share that information with banks.
The employer contended the records were “inherently discoverable” and that the trial court’s ruling was based on flawed reasoning, improperly prioritizing privacy concerns over the relevance of the information. Additionally, it argued that the trial court failed to correctly apply the standard governing discovery disputes.
Anderson responded by defending the trial court’s ruling, stating that the court correctly applied the law and exercised its discretion in evaluating the scope of discovery. He noted that the employer had already obtained income information through granted discovery requests and that less intrusive means were available to gather any additional relevant data.
Anderson also accused the employer of filing a frivolous appeal, arguing that it had little chance of success and was not based on a legitimate claim of judicial error.
The Appeals Board ultimately affirmed the trial court’s decision, concluding that it properly weighed the employer’s need for information against the privacy rights of Anderson and his family. The court emphasized that discovery must be relevant and proportionate to the needs of the case, as outlined in Rule 26 of the Tennessee Rules of Civil Procedure.
It agreed that the employer’s discovery requests were excessive in light of the available alternatives. Furthermore, the Board rejected the claim that the appeal was frivolous, finding that, although unsuccessful, the employer had raised arguable legal issues. As a result, the Board affirmed the trial court’s ruling in full, denied the employee’s request for attorneys’ fees, and remanded the case for further proceedings, with costs of the appeal assessed to the employer.
If you’re dealign with legal matters of your own and are in search of an experienced Knoxville workers’ compensation lawyer, contact us to reach out to The Lawyers of Brown & Roberto.