Henry, Martin v. Kirby Buildling Sustems

2025 TN WC 76
CourtTennessee Court of Workers' Compensation Claims
DecidedNovember 5, 2025
Docket2025-60-2682
StatusPublished

This text of 2025 TN WC 76 (Henry, Martin v. Kirby Buildling Sustems) 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
Henry, Martin v. Kirby Buildling Sustems, 2025 TN WC 76 (Tenn. Super. Ct. 2025).

Opinion

FILED

November 5, 2025

TN COURT OF WORKERS’ COMPENSATION CLAIM

1:09 PM (CT)

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

AT NASHVILLE

Henry Martin, Docket No. 2025-60-2682 Employee,

V.

Kirby Building Systems, State File No. 2304-2024 Employer,

and

Arch Indemnity Ins. Co., Judge Kenneth M. Switzer

Carrier.

COMPENSATION ORDER GRANTING BENEFITS

The Court held a compensation hearing on October 29, 2025, on the sole issue of Henry Martin’s entitlement to future medical benefits and whether this dispute is ripe. The Court finds that it is and holds that Mr. Martin is entitled to lifetime medical benefits.

Claim History

On January 7, 2024, Mr. Martin injured his thumb while working for Kirby Building Systems. He later filed a petition seeking a final medical report from the treating physician, Dr. Todd Rubin, and resolution of the permanency issues.

The dispute certification notice listed the compensation rate as an issue, but no monetary benefits are owed. It additionally listed medical benefits as an issue but acknowledged that Mr. Martin was treating. The mediator attached correspondence from Kirby Building Systems’ attorney stating: “Employee is seeking an order ensuring his future right to medical treatment in excess of the statutory right but did not dispute there was any active issue with medical benefits.”

Mr. Martin was released at maximum medical improvement with a 0% impairment rating. Ata previous scheduling hearing, Kirby Building Systems’ attorney agreed that no dispute exists as to compensability, the impairment rating, or entitlement to temporary disability and past medical benefits. The parties later filed stipulations as follows: No disputes exist as to temporary disability benefits; no treatment denials are pending; and Mr. Martin is unaware of any outstanding expenses on his claim.

1 Mr. Martin requested that he finalize the case with an order memorializing his right to lifetime open medical benefits. He argued that, without an order, if he needs treatment after the statute of limitations has passed, he could not receive it.!

In contrast, Kirby Building Systems seeks dismissal of the petition. It argued that section 50-6-204 already guarantees a right to medical benefits, so an order is unnecessary. Further, it contended that no disputes exist so that the case is not properly before the Court under the ripeness doctrine.

Findings of Fact and Conclusions of Law

Mr. Martin must show by a preponderance of the evidence that he is entitled to open medical benefits. Tenn. Code Ann. § 50-6-239(c)(6) (2024).

The statute and longstanding caselaw from the Tennessee Supreme Court provide that even when an employee retains no permanent impairment, as in this case, the employer remains responsible for future medical treatment of a work injury. Id. § 50-6-204(b)(1); Barron v. State Dep’t of Human Servs., 184 $.W.3d 219, 223 (Tenn. 2006).

Further, since passage of the Reform Act, the Appeals Board has similarly held, “Unless a court terminates an employee’s entitlement to medical benefits or approves a settlement in which the parties reach a compromise on the issue of future medical benefits, an injured worker remains entitled to reasonable and necessary medical treatment causally related to the work injury.” Limberakis v. Pro-Tech Sec., Inc., 2017 TN Wrk. Comp. App. Bd. LEXIS 53, at *7 (Sept. 12, 2017) (Emphasis added).

This case cannot remain on the docket indefinitely. The Appeals Board has explained, “[T]rial courts have been charged with controlling the pace of litigation through the use of supervision and docket management which will ensure efficient disposition of civil cases.” Smith v. The Newman Grp., 2015 TN Wrk. Comp. App. Bd. LEXIS 30, at *9 (Sept. 21, 2015) (Emphasis added). Regarding the methods of disposition, “there are only four possible resolutions of the petition in the Court of Workers’ Compensation Claims: adjudication by a judge; settlement of the claim approved by a judge; a nonsuit or voluntary dismissal of the claim; or involuntary dismissal of the claim.” Taylor v. Am. Tire Distrib.’s, 2017 TN Wrk. Comp. App. Bd. LEXIS 48, at *5-6 (Aug. 15, 2017). Of these four, Mr. Martin seeks adjudication.

1 Mr. Martin additionally moved for a “directed verdict,” referring to an involuntary dismissal under Rule 41.02 of the Tennessee Rules of Civil Procedure. Allen v. United Cabinet Corp., LLC, 2024 TN Wrk. Comp. App. Bd. LEXIS 12, at *3 (Mar. 19, 2024). Rule 41.02(2) (2024) provides in part: “After the plaintiff in an action tried by the court without a jury has completed the presentation of plaintiffs evidence, the defendant . .. may move for dismissal on the ground that upon the facts and the law the plaintiff has shown no right to relief.” The rule by it plain language is inapplicable, so the motion is denied.

2 Kirby Building Systems contended that the case cannot be adjudicated because no disputes currently exist, so the case is not ripe. The Court disagrees.

The ripeness doctrine assists courts in determining whether a particular case presents a justiciable legal issue. It “focuses on whether the dispute has matured to the point that it warrants a judicial decision. The central concern of the ripeness doctrine is whether the case involves uncertain or contingent future events that may or may not occur as anticipated or, indeed, may not occur at all.” Cotton v. HumaCare, Inc., 2016 TN Wrk. Comp. App. Bd. LEXIS 42, at *10-11 (Sept. 14, 2016) (Citations omitted). The Supreme Court gave a two-part test to determine if an issue is ripe for judicial review: 1) whether the issues in the case are ones appropriate for judicial resolution; and 2) whether the court’s refusal to act will cause hardship to the parties. B & B Enters. of Wilson Cnty., LLC v. City of Leb., 318 S.W.3d 839, 848-849 (Tenn. 2010).

Here, Kirby Building Systems sought dismissal of the petition on the basis of its professed willingness—essentially just a promise—to provide all benefits Mr. Martin is entitled to under the law. Recognizing the difficulty of seeking to enforce a promise, Mr. Martin reasonably requested a court order instead, if and when he needs future medical treatment.

This dispute has matured to the point where it warrants a judicial determination. Mr. Martin has completed treatment and been assigned a rating, which is the typical point where cases either settle or proceed to a compensation hearing. Mr. Martin might or might not need further treatment. But that can be said of almost all cases that seek a final adjudication in workers’ compensation.

As to whether the Court’s refusal to act would result in a hardship to the parties, Mr. Martin’s lack of an order memorializing his right to open medical benefits causes him hardship, in that right now, it places him on a lesser footing than an injured worker who has obtained an order confirming this benefit. He has no writing for a future court to enforce relative to this date of injury.

Kirby Building Systems argued that Mr. Martin can simply file another petition if treatment is denied in the future. That would force Mr. Martin to bring a whole other lawsuit, mediate the claim, and potentially litigate the issue (possibly without legal representation), which is a hardship. He also might face an insurmountable defense, including the statute of limitations, if a latent condition does not manifest within the timeframe in section 50-6-203.

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Related

B & B Enterprises of Wilson County, LLC v. City of Lebanon
318 S.W.3d 839 (Tennessee Supreme Court, 2010)

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Bluebook (online)
2025 TN WC 76, Counsel Stack Legal Research, https://law.counselstack.com/opinion/henry-martin-v-kirby-buildling-sustems-tennworkcompcl-2025.