Kean, Carma v. McRocket, LLC, dba Great Clips

Opinion

FILED Aug 20, 2026 08:00 AM(CT) TENNESSEE

WORKERS' COMPENSATION

APPEALS BOARD

TENNESSEE BUREAU OF WORKERS’ COMPENSATION WORKERS’ COMPENSATION APPEALS BOARD

Carma Kean Docket No. 2025-60-1190

v. State File No. 860045-2025

McRocket, LLC, d/b/a Great Clips, et al.

Appeal from the Court of Workers’ Compensation Claims Joshua D. Baker, Judge

Affirmed and Remanded

In this interlocutory appeal, the employee questions the trial court’s order requiring her to sign medical records releases. The employee alleged an injury to her finger in the course and scope of her position as a hairdresser for the employer. The employer initially accepted the claim as compensable and provided certain benefits to the employee. After the authorized physician opined the employee’s condition was not primarily caused by her work, the employer ceased providing benefits. The employee then filed a petition for benefits, and, following an expedited hearing, the trial court determined the employee was unlikely to prove at a hearing on the merits that her finger injury was primarily caused by her employment. That order was not appealed, and the parties proceeded with discovery. With respect to the current appeal, the employee declined to sign medical records releases, arguing that most of her prior medical records were irrelevant to her claim for benefits. Following a hearing on the employer’s motion to compel, the court ordered her to sign the releases. The employee signed the requested releases but added language limiting the scope of the releases. The employer then filed another motion to compel, and the court ordered the employee to sign releases for six medical providers for all medical records from the last ten years. The employee has appealed. Having carefully reviewed the record, we affirm the trial court’s decision and remand the case.

Judge Meredith B. Weaver delivered the opinion of the Appeals Board in which Presiding Judge Timothy W. Conner and Judge Pele I. Godkin joined.

Carma Kean, employee-appellant, pro se

Kitty Boyte, Brentwood, Tennessee, for the employer-appellee, McRocket, LLC, d/b/a Great Clips

2

Memorandum Opinion1

The issue in this appeal is limited to a discovery order and, as such, the factual and procedural history is provided for context only. Carma Kean (“Employee”) works as a hairdresser for McRocket, LLC, d/b/a Great Clips (“Employer”). Employee previously suffered a right wrist injury with another employer in 2022, and in August of 2024, Employee returned to Dr. Tyler Staelin, her authorized treating physician for that claim. Her primary complaint was that her right middle finger had been popping and catching. Dr. Staelin diagnosed Employee with trigger finger but opined it was not caused by her 2022 injury, although he observed it was “likely related” to her work as a hairdresser and stylist.

Employee reported the new claim to Employer, and Employer provided a panel, from which she chose an urgent care clinic, Care Now. The providers there referred her for an orthopedic evaluation, and Employer provided a panel from which Employee chose Dr. Keith Douglas. Dr. Douglas saw Employee on December 2, 2024. He agreed with the trigger finger diagnosis and provided an injection. However, he stated that her condition was “a common condition seen in people of all ages and occupations” and opined it was not primarily caused by her work for Employer.

Employer denied further benefits, and Employee filed a petition for benefit determination in February 2025. After an expedited hearing, the trial court issued an order denying benefits on August 12, 2025. The court determined Employee was unlikely to be successful at trial given the absence of medical proof establishing her trigger finger was primarily caused by her employment. That order was not appealed.

Thereafter, the parties engaged in written discovery, and Employer filed numerous motions to compel. Employee did not fully complete her interrogatory responses, and, when asked to sign medical releases for any providers she listed in response to specific interrogatories, she only did so for certain providers. In March, following a hearing on a motion to compel filed by Employer, the court ordered Employee to list all of her medical providers over the last five years. That order was not appealed. Employer then filed a motion in April, asking the court to compel Employee to sign medical releases to allow Employer to obtain her medical records from the providers she had been compelled to identify. The court granted the motion, which was not appealed. Pursuant to that order, Employee signed the releases, but she added language to the releases limiting them to “records relating to [the] ‘right hand’[] to 10 years prior to [September 17, 2025].”2

1 This decision is being filed pursuant to Tenn. Comp. R. and Regs. 0800-02-22-.03(1) (2023).

2 Employee did not appeal this order but asked the trial court for clarification, as the initial order did not list the names of the providers. The trial court issued an amended order the following day, April 23, 2026, identifying the specific providers for which Employee was ordered to sign a release. That order also was not appealed.

3

Employee’s revision of the releases prompted Employer to file another motion to compel, asking the court to order Employee to sign the original, unrevised releases. The court held a hearing and, on June 9, 2026, ordered Employee to comply, stating Employer was entitled to the information as it “is reasonable, relevant, and likely to lead to the discovery of admissible evidence.” Employee has appealed.

It is well settled that the scope of pretrial discovery is generally broad. See, e.g., Hernandez v. Wal-Mart Associates, Inc., No. 2024-30-6638, 2026 TN Wrk. Comp. App. Bd. LEXIS 9, at *15 (Tenn. Workers’ Comp. App. Bd. Feb. 27, 2026). A request for discovery need only show that the information sought would lead to admissible evidence, and thus the rules for discovery are to be liberally construed. See Estate of Guinn v. Barnard Roofing Company, Inc., No. 2017-02-0207, 2017 TN Wrk. Comp. App. Bd. LEXIS 59, at *6-7 (Tenn. Workers’ Comp. App. Bd. Oct. 5, 2017) (internal citations omitted). A trial court’s decisions regarding pretrial discovery are discretionary and will be reviewed under an “abuse of discretion” standard. Doe 1 ex rel. Doe 1 v. Roman Cath. Diocese of Nash., 154 S.W.3d 22, 42 (Tenn. 2005). An abuse of discretion is found if the trial court “applied incorrect legal standards, reached an illogical conclusion, based its decision on a clearly erroneous assessment of the evidence, or employ[ed] reasoning that causes an injustice to the complaining party.” Konvalinka v. Chattanooga-Hamilton Cnty. Hosp. Auth., 249 S.W.3d 346, 358 (Tenn. 2008).

Here, we conclude there is a clear, rational connection between Employer’s request for medical releases and Employee’s past medical history for a condition that a medical expert has identified as “common.” By filing her claim for benefits, Employee has placed her physical condition in dispute, and Employer is entitled to discover potentially relevant information about Employee’s physical condition as it existed prior to the alleged work injury. In short, given that discovery in Tennessee is generally broad and the rules governing discovery are to be liberally construed, we conclude the trial court did not abuse its discretion when it ordered Employee to sign the requested medical releases.

For the foregoing reasons, we affirm the decision of the trial court and remand the case. Costs on appeal are taxed to Employee.