DAVIDSON, JAMES v. GIBSON GUITAR

2025 TN WC 2
CourtTennessee Court of Workers' Compensation Claims
DecidedJanuary 28, 2025
Docket2024-60-3877
StatusPublished

This text of 2025 TN WC 2 (DAVIDSON, JAMES v. GIBSON GUITAR) is published on Counsel Stack Legal Research, covering Tennessee Court of Workers' Compensation Claims primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DAVIDSON, JAMES v. GIBSON GUITAR, 2025 TN WC 2 (Tenn. Super. Ct. 2025).

Opinion

FILED Jan 28, 2025 02:07 PM(CT) TENNESSEE COURT OF WORKERS' COMPENSATION CLAIMS

TENNESSEE BUREAU OF WORKERS’ COMPENSATION CLAIMS IN THE COURT OF WORKERS’ COMPENSATION CLAIMS AT NASHVILLE

JAMES DAVIDSON, ) Docket No. 2024-60-3877 Employee, ) v. ) ) State File No. 74711-2022 GIBSON GUITAR, ) Employer. ) ) Judge Joshua D. Baker

EXPEDITED HEARING ORDER

At a January 8 expedited hearing, Mr. Davidson requested medical and temporary disability benefits, penalties, and attorneys’ fees. For the reasons below, the Court holds Mr. Davidson is likely to prevail on medical benefits and awards attorneys’ fees for Gibson’s failure to initiate medical benefits timely. Gibson is also referred to the Compliance Program for consideration of penalties. The Court holds Mr. Davidson’s proof was insufficient to find he is likely to prevail on temporary disability benefits at this time.

Claim History

Mr. Davidson injured his left shoulder while working for Gibson on September 29, 2022. He selected a walk-in clinic from a panel.

Initially the physician’s assistant restricted him from using his left arm, and Gibson offered light-duty work. Mr. Davidson struggled using only one arm on light duty, so Gibson sent him home. After that, he kept human resources updated by dropping his work restrictions in an inbox or sometimes handing them directly to a human resources representative. Gibson did not offer him light duty again after that first failed attempt. However, a medical note from the walk-in clinic stated that Mr. Davidson had “chosen not to return to work.”

Gibson’s plant safety manager, Jeremy Hatcher, testified but did not offer any specific or detailed information about Mr. Davidson’s claim, saying only that light-duty changes day to day and is available to most injured workers. However, he did not elaborate on how injured workers are assigned light-duty work or supposed to know which work is available. Summarily, Mr. Hatcher implied that it was a worker’s responsibility to show up at the plant and see if light-duty work that suited their restrictions were available. However, when and how often workers needed to come to the plant in search of light-duty work was not discussed.

While Mr. Davidson was out of work, he continued to treat at a walk-in clinic. One month after the accident after an MRI, the physician’s assistant at the clinic recommended an orthopedist. During the last visit at the walk-in clinic, about two months after the work injury, the physician’s assistant noted Mr. Davidson was still “[a]waiting orthopedic eval.”

But Mr. Davidson did not receive a panel of orthopedists, and treatment stopped. He testified that after the orthopedic referral, the adjuster stopped communicating with him, asserting his injury was preexisting. Gibson did not produce a notice of denial.

Despite the adjuster’s decision to deny the claim, Gibson continued to pay Mr. Davidson for an unspecified time after the accident, Mr. Davidson said he received inconsistent payments by direct deposit. He could not recall an exact amount or total or say what the payments were for, but he knew they were from Gibson and not the insurance carrier. He said the payments stopped sometime before he received a termination letter. Gibson did not produce any documents or provide any testimony about the purpose of these payments.

Almost two years after Mr. Davidson’s injury and when he filed a petition for benefits, Gibson offered an orthopedist panel and authorized an evaluation with Dr. Brian Koch. At trial, the parties stipulated that Dr. Koch is an authorized treating physician.

On August 16, 2024, more than 22 months after Mr. Davidson’s accident, Dr. Koch examined him and observed a labral tear on his 2022 MRI. About causation, Dr. Koch wrote, “I do believe that it is greater than 51% likely that his injury at work was the cause of his pain and labral tear . . . He states that he is not currently working so work restriction[s] at this point are irrelevant.”

A month later, after comparing the 2022 MRI with updated imaging, Dr. Koch recommended a left-shoulder labral repair. He wrote of Mr. Davidson’s condition, “He has continued to have pain, has not improved over the past couple of years. I believe he would benefit from surgical intervention.” Gibson did not provide the surgery.

Findings of Fact and Conclusions of Law

Mr. Davidson must prove he is likely to prevail at a final hearing on his requested benefits. Tenn. Code Ann. § 50-6-239(d)(1) (2024); McCord v. Advantage Human Resourcing, 2015 TN Wrk. Comp. App. Bd. LEXIS 6, at *7-8, 9 (Mar. 27, 2015). He is seeking medical benefits, temporary disability benefits, a penalty assessment under section 50-6-205(b)(3)(A), and attorney’s fees under section 50-6-226(d)(1)(B).

Medical Benefits

An employer “shall furnish, free of charge to the employee, such medical and surgical treatment . . . made reasonably necessary by accident[.]” Tenn. Code Ann. § 50- 6-204(a)(1)(A).

Although Gibson accepted Mr. Davidson’s claim and gave him a panel of physicians, it did not offer an orthopedic panel “within three (3) business days” under section 50-6-204(a)(3)(A)(ii) after his selected provider referred him to an orthopedist. Instead, it offered the panel almost two years later, only after he filed a petition.

Gibson argued Mr. Davidson cannot prevail because he has not proven medical causation between his work injury and his present condition. But “an employer’s assertion that an employee has no medical evidence supporting his or her claim does not, standing alone, excuse it from [its] statutory obligations under section 50-6-204(a)(1)(A) and sounds hollow.” Hawes v. McLane Co., Inc., 2021 TN Wrk. Comp. App. Bd. LEXIS 30, at *9-10 (Aug. 25, 2021).

Further, expert medical evidence directly contradicts Gibson’s hollow assertion. Dr. Koch, an orthopedist, compared both MRIs and concluded Mr. Davidson suffered a work injury and needs surgery. His opinion is the only expert interpretation of the medical evidence. Moreover, his opinion on medical causation and treatment recommendations is presumed correct. Tenn. Code Ann. §§ 50-6-102(13)(E), 50-6-204(a)(3)(H).

Gibson presented no evidence to refute Dr. Koch’s opinion and relied solely on their own interpretation to deny recommended treatment. As the Appeals Board has stated, “parties and their lawyers cannot rely solely on their own medical interpretations of the evidence to successfully support their arguments.” Lurz v. Int’l Paper Co., 2018 TN Wrk. Comp. App. Bd. LEXIS 8, at *17 (Feb. 14, 2018).

Given Dr. Koch’s opinion, Mr. Davidson is likely to prevail at trial in proving surgery is reasonable and necessary treatment for his work injury. So, Gibson must furnish continuing medical treatment with Dr. Koch including the recommended left-shoulder labral-repair surgery.

Temporary Disability Benefits

Where a treating physician has released an injured worker to return to work with restrictions before maximum recovery and the employer cannot return the employee to work within the restrictions, the injured worker may be eligible for temporary partial disability. Heard v. Carrier Corp., 2018 TN Wrk. Comp. App. Bd. LEXIS 16, at *5 (Apr. 20, 2018).

The trial court must consider whether an employee has made a “meaningful return to work” by assessing “the reasonableness of the employer in attempting to return the employee to work and the reasonableness of the employee in failing to return to work.” Hackney v.

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Related

§ 50
Tennessee § 50
§ 50-6
Tennessee § 50-6
§ 50-6-102
Tennessee § 50-6-102(13)(E)
§ 50-6-239
Tennessee § 50-6-239(d)(1)

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Bluebook (online)
2025 TN WC 2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/davidson-james-v-gibson-guitar-tennworkcompcl-2025.