Hall, Phillip v. Life Care Centers of America, Inc.

2018 TN WC 164
CourtTennessee Court of Workers' Compensation Claims
DecidedOctober 9, 2018
Docket2018-02-0063
StatusPublished

This text of 2018 TN WC 164 (Hall, Phillip v. Life Care Centers of America, Inc.) 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
Hall, Phillip v. Life Care Centers of America, Inc., 2018 TN WC 164 (Tenn. Super. Ct. 2018).

Opinion

FILED Oct 09, 2018 11:40 AM(CT) TENNESSEE COURT OF WORKERS' COMPENSATION CLAIMS

TENNESSEE BUREAU OF WORKERS' COMPENSATION IN THE COURT OF WORKERS' COMPENSATION CLAIMS AT GRAY

PHILLIP HALL, ) Docket Number: 2018-02-0063 Employee, ) v. ) LIFE CARE CENTERS OF ) State File Number: 98623-2017 AMERICA, INC., ) Employer, ) and ) OLD REPUBLIC INSURANCE CO., ) Judge Brian K. Addington Carrier. )

EXPEDITED HEARING ORDER

This case came before the Court on October 4, 2018, on Phillip Hall's Request for Expedited Hearing. The issue is whether he is entitled to temporary partial disability benefits. For the reasons below, the Court holds that Mr. Hall is not likely to prevail at a hearing on the merits in proving that he is entitled to the requested benefits.

History of Claim

Life Care hired Mr. Hall as a certified nursing assistant in October 2017. He alleged three injuries before his employment ended in April 2018. For the purposes of this hearing, the parties focused on Mr. Hall's January 10, 2018 right great-toe fracture and his April 4, 2018 back injury. Life Care did not dispute the injuries occurred at work.

Dr. Jeffrey Dikis treated Mr. Hall's toe. He restricted his work duties and placed him in a walking boot, which exposed his toes. Life Care provided light-duty work after the injury. Mr. Hall reinjured his toe at work on March 14 when he hit it on a stool. He testified he fell at least four times after January 10 due to the injury and the boot.

During this time, Mr. Hall underwent work-related problems with other employees. He and co-workers complained about each other. The situation worsened and Life Care conducted an investigation. Mr. Hall admitted that he and a co-worker

1 argued over a bonus that Life Care paid the co-worker. 1 Mr. Hall denied making inappropriate comments towards co-workers. He insisted they misconstrued his words. He accused them of making sexual, rude comments towards him and touching him. Several co-workers' statements indicated Mr. Hall often made sexual or inappropriate comments at work. 2

During the evening of April 3, Life Care decided to suspend Mr. Hall. Misty Key, Executive Director, tried to contact him but was unable to reach him by phone. When Mr. Hall reported to work the next morning, Ms. Key asked him into a meeting and suspended him for conduct that created a poor image for the facility. Before the meeting, Mr. Hall slipped on a wet floor due to the boot. After his suspension, Mr. Hall called from home and requested treatment for back pain.

Mr. Hall treated with Takoma Health Systems on April 4 for his back. Providers there restricted him to work where he could sit. Later, Life Care authorized Dr. Craig Schmalzreid to treat his back injury.

Before seeing Dr. Schmalzreid, Life Care terminated Mr. Hall on April 9 for a code of conduct violation, which it described as "[P]oor image for the facility."

Later, Mr. Hall saw Dr. Schmalzreid, who diagnosed his back injury as acute pain and sciatica and assigned restrictions.

Meanwhile, Dr. Dikis placed Mr. Hall at maximum medical improvement for his toe and released him to full duty on April 20. Dr. Schamlzreid released him to full duty work on April 26.

Life Care paid temporary partial disability benefits from April 4-20 for his toe injury. Mr. Hall requested temporary partial disability benefits from April 4-26 for his back, even though he received temporary partial benefits from April 4-20. He argued that he suffered two different injuries, so he was entitled to two separate disability payments, even if the times overlapped. He argued his back injury would not have occurred if Life Care followed its no open-toe shoe policy. Life Care argued Mr. Hall was not entitled to additional temporary partial disability benefits because it accommodated his restrictions before it terminated him.

Findings of Fact and Conclusions of Law

At an expedited hearing, Mr. Hall has the burden to present sufficient evidence 1 Life Care offered a bonus to employees who referred successful job applicants. 2 The Court gleaned this information from part of Mr. Hall's employment file, which entered the record as exhibit 9 without objection.

2 from which this Court can determine that he is likely to prevail at a hearing on the merits. McCord v. Advantage Human Resourcing, 2015 TN Wrk. Comp. App. Bd. LEXIS 6, at *7-8, 9 (Mar. 27, 2015).

Before addressing the temporary benefits issue, the Court notes that although parties identified two distinct injury dates, the Court finds Mr. Hall's injury date is January 10, 2018. Mr. Hall testified he fell at least four times due to the injury to his great toe and boot. According to Mr. Hall, the boot slip on the wet floor at work is what caused him to injure his back. Therefore, the April 4 event is a natural consequence of his toe injury and not a distinct new injury. See Anderson v. Westfield Grp., 259 S.W.3d 690, 696-7 (Tenn. 2008).

Mr. Hall requested temporary partial disability, which refers to the time, if any, during which the injured employee is able to resume some gainful employment but has not reached maximum recovery." Frye v. Vincent Printing Co., 2016 TN Wrk. Comp. App. Bd. LEXIS 34, at *15-16 (Aug. 2, 2016.) He requested the period from April4-26, even though Life Care paid him temporary partial disability benefits from April 4-20. Mr. Hall did not present any statute or case law indicating an employee is entitled to multiple temporary disability payments for the same time period, and the Court is unaware of any. Therefore, the Court denies his request for additional temporary disability benefits solely for the back injury for April 4-20. This leaves his request for April 21-26.

Concerning the latter period, Mr. Hall presented a physician's note indicating Dr. Schmalzreid restricted his work for that time period, and he testified he did not work due to his termination. Life Care did not dispute these facts.

However, even though an employee has a work-related injury for which temporary benefits are payable, an employer may still enforce workplace rules. Thus, a termination due to a violation of workplace rules may relieve an employer of its obligation to provide temporary partial disability benefits, provided the termination was related to the workplace violation. Courts must "consider the employer's need to enforce workplace rules and the reasonableness of the contested rules." An employer will not be penalized for enforcing a policy if the court determines "( 1) that the actions allegedly precipitating the employee's dismissal qualified as misconduct under established or ordinary workplace rules and/or expectations; and (2) that those actions were, as a factual matter, the true motivation for the dismissal." See Jones v. Crencor Leasing and Sales, 2015 TN Wrk. Comp. App. Bd. LEXIS 48, at *7-9 (Dec. 11, 2015).

Here, Life Care terminated Mr. Hall for creating a poor image for the facility. Essentially, Life Care accused him of making remarks that were inappropriate in the workplace. These not only included sexual, rude comments but also remarks concerning a bonus Life Care paid another employee when it hired Mr. Hall. Mr. Hall did not deny

3 he confronted the other employee about the bonus. Although he explained he did not make the other comments or that the person hearing the comments wrongly construed them, multiple co-workers' statements contradicted Mr. Hall. The Court finds Mr. Hall made inappropriate remarks that violated ordinary workplace expectations, and this was Life Care's true motivation for his dismissal.

The Court finds the termination reasonable and unrelated to his worker's compensation claim.

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Related

Anderson v. Westfield Group
259 S.W.3d 690 (Tennessee Supreme Court, 2008)

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2018 TN WC 164, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hall-phillip-v-life-care-centers-of-america-inc-tennworkcompcl-2018.