HANDS, DERRICK v. FRESENIUS MEDICAL CARE HOLDINGS, INC

2026 TN WC 11
CourtTennessee Court of Workers' Compensation Claims
DecidedFebruary 19, 2026
Docket2020-08-0199
StatusPublished

This text of 2026 TN WC 11 (HANDS, DERRICK v. FRESENIUS MEDICAL CARE HOLDINGS, 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
HANDS, DERRICK v. FRESENIUS MEDICAL CARE HOLDINGS, INC, 2026 TN WC 11 (Tenn. Super. Ct. 2026).

Opinion

FILED Feb 19, 2026 11:01 AM(CT) TENNESSEE COURT OF WORKERS' COMPENSATION CLAIMS

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

DERRICK HANDS, ) Docket No. 2020-08-0199 Employee, ) v. ) FRESENIUS MEDICAL CARE ) HOLDINGS, INC., ) Employer, ) State File No. 91566-2018 And ) AMERICAN CASUALTY COMPANY ) OF READING, PA, ) Carrier, ) And ) Judge Shaterra R. Marion TROY HALEY, as ) ADMINISTRATOR of the BUREAU ) OF WORKERS’ COMPENSATION, ) SUBSEQUENT INJURY AND ) VOCATIONAL RECOVERY FUND. )

COMPENSATION ORDER

The Court held a Compensation Hearing on February 5, 2026, on Mr. Hands’s entitlement to medical and permanent disability benefits for his knee and back injuries. 1 Mr. Hands argued that his injuries (knee and back) arose primarily out of and in the course and scope of his employment and that he is permanently and totally disabled. Fresenius and the Subsequent Injury Fund argued the knee did, but the back did not, and the disability is only partial.

The Court finds that Mr. Hands’s knee and back injuries arose primarily out of and in the course and scope of his employment, and he is partially disabled.

1 The parties agreed to the compensability, future medical, and permanent benefits for his knee injury. 1 History of Claim

Mr. Hands fell at work on November 12, 2018. He hurt his knee and back and selected Dr. Frederick Wolf from a panel.

Dr. Wolf primarily treated Mr. Hands’s knee injury; but at his first visit he noted Mr. Hands suffered “new and fresh” back pain radiating into his buttocks. An x-ray showed “chronic findings,” but Dr. Wolf noted that Mr. Hands “had this injury and now he has a lot of symptoms. He’s very symptomatic.”

Dr. Wolf ordered injections for Mr. Hands’s back, and when those did not relieve his symptoms, Dr. Wolf referred Mr. Hands to orthopedic spine surgeon Dr. Spencer Hauser. Dr. Wolf deferred to Dr. Hauser on causation for the back injury.

Dr. Wolf placed Mr. Hands at maximum medical improvement for his knee, assigned a 1% impairment, and released him with no restrictions.

Dr. Hauser took x-rays, including standing lumbar flexion-extension x-rays, and an MRI. He found back pain radiating down Mr. Hands’s legs with extension and straight leg raise. He testified that the MRI showed evidence of nerve root compression and he recommended lumbar fusion surgery.

Fresenius sent Mr. Hands to Dr. John Brophy, a neurosurgeon, for a second opinion on surgery. Dr. Brophy did not relate the back pain to the work injury, based on a lack of anatomical change and the presence of a preexisting chronic back condition.

Dr. Brophy testified that he did not “specifically recall” reviewing Dr. Hauser’s records before reaching his conclusion. Rather, he based his opinion on his independent review of the MRI and his in-person examination. If lumbar flexion-extension x-rays showed evidence of motion, then the lumbar fusion surgery would probably help.

Mr. Hands continued to see Dr. Hauser for unauthorized treatment including the lumbar fusion surgery. The surgery helped at first, but the back pain did not go away. Physical therapy and pain management did not help either. Dr. Hauser ordered a CT scan and a new MRI. He discussed a spinal cord stimulator and possible revision surgery. Mr. Hands opted for the stimulator, which also did not help.

Dr. Hauser testified at a November 10, 2023 deposition that Mr. Hands was probably at maximum medical improvement but needed an examination. That examination took place on December 6, and Dr. Hauser assigned a 12% impairment rating at an October 4, 2024 deposition. He agreed with Dr. Brophy that the MRIs showed no evidence of an acute injury. However, he related Mr. Hands’s back injury to his work injury because “he had no prior history of any back or radiating leg pain prior to this injury.” He placed no

2 permanent restrictions.

Fresenius also sent Mr. Hands to Dr. Samuel Murrell, an orthopedic surgeon, for an employer’s exam. Like Dr. Brophy, Dr. Murrell concluded that the back pain is not related to the work injury. He related the back pain to an underlying degenerative condition.

Dr. Murrell testified Mr. Hands suffered a lumbar strain and he “would have expected that to resolve within six to 12 weeks if not sooner.” He also stated that he “can’t really explain” what might have caused his ongoing complaints of back pain.

Mr. Hands testified that he has not returned to work since his injury and does not believe he can do any job. His past work experience includes working as a cook and a delivery driver. He called his boss and told him that he could not work anymore.

Findings of Fact and Conclusions of Law

Motion in Limine

Shortly before the compensation hearing, Mr. Hands renewed a motion in limine to exclude utilization review documents attached as an exhibit to Dr. Hauser’s deposition. Fresenius opposed the motion. In an order after the original motion, the Court reserved final ruling until the compensation hearing. At the compensation hearing, the Court ruled that exhibit three of Dr. Hauser’s deposition was admissible. However, after reconsideration, the exhibit is excluded.

At his deposition, Dr. Hauser testified that the utilization review records are kept as part of the ordinary course of business in his office. He recognized them and agreed that the statements were made for the purposes of medical diagnosis and treatment. However, Rule 803(6) requires the conditions to be shown by the custodian of the record or a qualified witness. Dr. Hauser had no duty to record or transmit the utilization review record nor is he the custodian.

Mr. Hands’s motion to exclude exhibit three to Dr. Hauser’s deposition is granted.

Causation

At this Compensation Hearing, Mr. Hands must prove all elements of his case by a preponderance of the evidence. Tenn. Code Ann. § 50-6-239(c)(6) (2025). He must show that his back pain arose primarily out of and in the course and scope of his employment. Id. § 50-6-102(12).

Mr. Hands relied on Dr. Hauser’s opinion that the injury, need for medical treatment, and permanent disability were all related to the work incident. Fresenius relied

3 on Drs. Brophy and Murrell, who found that the injury was not work-related and the medical treatment was not medically necessary. Dr. Brophy stated that the lumbar fusion would probably help if a flexion extension x-ray showed motion, but he was unaware that the x-ray took place and did show motion.

Dr. Hauser is not entitled to a presumption of correctness on causation, as he was a direct referral from Dr. Wolf and not a panel-selected physician. Id. § 50-6-102(12)(E); Gilbert v. United Parcel Serv., 2019 TN Wrk. Comp. App. Bd. LEXIS 20, at *13 (June 7, 2019). However, his opinion on medical necessity is presumed correct. Id. § 50-6- 204(a)(3)(H).

When faced with conflicting medical testimony, the Court must use its discretion in deciding which opinion contains the more probable explanation. Sanker v. Nacarato Trucks, Inc., 2016 TN Wrk. Comp. App. Bd. LEXIS 27, at *12 (July 6, 2016).

An injury is defined as “causing death, disability, or the need for medical treatment.” Id. § 50-6-102(12). A preexisting condition made symptomatic by a work injury may be compensable “if there is a progression or aggravation of the condition that causes disabling pain.” Blevins v. S. Champion Tray, LP, 2019 TN Wrk. Comp. App. Bd. LEXIS 29, at *14 (July 11, 2019).

Further, an aggravation injury could cause the need for medical treatment without an anatomical change. Edwards v. Peoplease, LLC, No. W2024-01034-SC-R3-WC 2025 Tenn. LEXIS 514, at *26 (Tenn. 2025).

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Bluebook (online)
2026 TN WC 11, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hands-derrick-v-fresenius-medical-care-holdings-inc-tennworkcompcl-2026.