Mitchell, Jr.,Clarence v. Knoxville Area Transit

2025 TN WC 77
CourtTennessee Court of Workers' Compensation Claims
DecidedNovember 7, 2025
Docket2025-30-0595
StatusPublished

This text of 2025 TN WC 77 (Mitchell, Jr.,Clarence v. Knoxville Area Transit) 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
Mitchell, Jr.,Clarence v. Knoxville Area Transit, 2025 TN WC 77 (Tenn. Super. Ct. 2025).

Opinion

FILED Nov 07, 2025 07:00 AM(CT) TENNESSEE COURT OF WORKERS' COMPENSATION CLAIMS

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

CLARENCE MITCHELL, JR., ) Docket No. 2025-30-0595 Employee, ) v. ) State File No. 5981-2024 KNOXVILLE AREA TRANSIT, ) Employer. ) Judge Lisa A. Lowe

EXPEDITED HEARING ORDER GRANTING BENEFITS

Clarence Mitchell suffered work-related left shoulder, wrist, and back injuries. At an Expedited Hearing, he sought additional temporary disability benefits. Knoxville Area Transit (KAT) denied his request because he failed to follow its transitional work program. However, the Court holds that Mr. Mitchell would likely prevail at a hearing on the merits on the transitional work issue and grants his request.

History of Claim

Mr. Mitchell worked as a bus driver for KAT. On January 23, 2024, he slipped on black ice while walking to his bus, hurting his left shoulder, wrist, and back. KAT accepted the claim.

Mr. Mitchell first treated with Dr. Paul Johnson for his back. Dr. Johnson offered surgery; however, Mr. Mitchell declined. He underwent therapy and injections and took medications. Dr. Johnson placed him at maximum medical improvement on August 7, 2024.

Dr. Johnson then retired, and Dr. Luke Madigan took over Mr. Mitchell’s back treatment. Mr. Mitchell testified that his pain continued during the gap between the two doctors. Dr. Madigan also recommended surgery, but Mr. Mitchell again declined. He placed Mr. Mitchell at maximum medical improvement on August 12, 2025.

For his left shoulder, Mr. Mitchell treated with Dr. Michael Casey. From February to April 2024, Dr. Casey recommended medication and physical therapy, and he assigned

1 restrictions. Ultimately Dr. Casey performed surgery on October 17. On October 28, Dr. Casey recommended physical therapy and assigned a restriction of “no use of injured arm.”

Mr. Mitchell, who worked for KAT for 14 years, testified KAT did not accommodate light-duty restrictions, so if a worker were assigned light duty, they would be sent home. However, at the end of January 2024, KAT implemented a new transitional work program.

Several witnesses testified that employees with any work-related issues look to the contract between KAT and the Union and KAT’s Handbook. The contract states in the third paragraph on page three:

The Company may implement and enforce reasonable rules and regulations; however, at least seven or more calendar days prior to implementation, the Company will submit the same to the Union for review. In addition, the Company will post the rule or regulation in a conspicuous place for each department impacted by the rule and/or regulation prior to the effective date. In the event the rules are not posted in accordance with the Agreement, said rule will not be in effect until the rule is posted in accordance with this Agreement.

Human Resource Specialist Synquis Harris testified that KAT did not post the new transitional work program. She also testified that she did not inform Mr. Mitchell about the new program because he was represented by an attorney at that time.

Additionally, paragraph 23 on page 25 of the contract states:

Excessive absences – the only absences not subject to the guidelines of the absence policy as defined in work rules are: miss-outs, suspensions, bona fide union business, approved leaves of absence, bereavement leave, military or jury duty, vacations, holidays, FMLA, paid sick leave and occupational illnesses or injury while working at [KAT].

On November 12, KAT sent Mr. Mitchell a letter offering transitional light-duty work with a local nonprofit. He testified he received the letter on November 15. The job description included: sorting, inventory, sizing clothes, stocking in the warehouse, and light cleaning. The letter directed Mr. Mitchell to report to the nonprofit on November 18, and it cautioned that declining light-duty work might affect his right to receive ongoing workers’ compensation benefits.

Mr. Mitchell did not believe he could return to light-duty work, as he was only four weeks out from surgery, on pain medications, and attending physical therapy. He testified he was still having a great deal of pain and trouble sleeping, and he felt rushed and

2 intimidated. He said he had never heard of this new policy, and coworkers told him that it had not been posted per the contract. Additionally, no language in the letter said that he could be terminated for failure to appear, and the contract exempts absences from a work injury from the excessive absence policy. So, he did not appear for the transitional work.

KAT terminated Mr. Mitchell on December 12 because he refused to perform the light-duty transitional work that “coincides with KAT’s attendance policy.” Mr. Mitchell has not worked since.

Findings of Fact and Conclusions of Law

Mr. Mitchell must show that he is likely to prevail at a hearing on the merits. 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).

For temporary partial disability benefits, Mr. Mitchell must show that his treating physician returned him to work with restrictions that KAT either could not or would not accommodate. Jones v. Crencor Leasing and Sales, 2015 TN Wrk. Comp. App. Bd. LEXIS 48, at *7, 8 (Dec. 11, 2015).

Employers may use transitional work programs. See Lasser v Waste Mgmt., 2018 TN Wrk. Comp. App. Bd. LEXIS 20, at *13 (May 24, 2018). However, the Court must address the reasonableness of KAT’s offer of transitional light-duty and the reasonableness of Mr. Mitchell’s refusal. The reasonableness of temporary transitional work is dependent upon the facts of each case. Id.

Even though KAT had the transitional work program in place in January or February 2024, it did not offer Mr. Mitchell transitional work while he was under restrictions from February to April. The first offer of transitional work came approximately a month after Mr. Mitchell’s surgery, while he was still taking pain medications, going to physical therapy, and restricted from using his left arm. The work duties included: sorting, inventory, sizing clothes, stocking in the warehouse, and light cleaning. The Court finds that Mr. Mitchell could not perform those tasks safely or effectively without the use of his left arm and while taking pain medication.

Further, Mr. Mitchell had no knowledge of KAT’s new transitional work program before receiving the offer letter. He knew that the contract required any change to be posted, and it was not. He also knew that the contract exempted him from excessive absences since he had a work injury.

Thus, the Court finds that based on his condition and what he knew about the posting requirement and exemption from KAT’s absenteeism policy, Mr. Mitchell will likely prove at a hearing on the merits that he was reasonable in declining the transitional light duty.

3 Mr. Mitchell’s average weekly wage was $1,407.94, which results in a compensation rate of $938.67. He last received temporary benefits on November 20, 2024, and Dr. Madigan placed him at maximum medical improvement on August 12, 2025. The Court finds that Mr. Mitchell is likely to prove entitlement to 38 weeks of temporary partial disability benefits, or $35,669.59.

IT IS, THEREFORE, ORDERED as follows:

1. Knoxville Area Transit shall provide medical care for Clarence Mitchell’s injuries as required by Tennessee Code Annotated section 50-6-204 (2024).

2. Knoxville Area Transit shall pay Mr. Mitchell past temporary partial disability benefits in the amount of $35,669.59.

3.

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Related

§ 50-6-239
Tennessee § 50-6-239(d)(1)

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2025 TN WC 77, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mitchell-jrclarence-v-knoxville-area-transit-tennworkcompcl-2025.