State News : Tennessee

January 2026

Tennessee Supreme Court Clarifies Compensability Standard for Aggravation of Pre-Existing Conditions

On December 22, 2025, the Tennessee Supreme Court issued the Edwards v. Peoplease, LLC. decision which provided much-needed clarification on the proof needed to establish a compensable aggravation of a pre-existing condition. 

In Edwards, the employee was a truck driver who was involved in a motor vehicle accident when one of her tires blew out. She received authorized medical treatment with Dr. Jason Hutchison, who diagnosed her with end-stage tricompartmental arthritis in both knees. Bilateral knee replacement surgeries were recommended. Dr. Hutchison opined that the knee arthritis was pre-existing, but that the accident “may have caused a significant exacerbation of the arthrosis.” However, Dr. Hutchison further opined that the exacerbation of knee symptoms was not compensable under the Tennessee Workers’ Compensation Law. Employer denied responsibility for the knee replacement surgeries under workers’ compensation.

The employee sought a second opinion with Dr. Timothy Sweo. Dr. Sweo agreed that knee replacement surgeries were appropriate, but Dr. Sweo opined that the need for both knee replacements was most likely greater than 51% caused by the work accident.

The trial court convened an expedited hearing and ruled that Ms. Edwards was likely to prevail on the merits. The trial court found that Dr. Hutchison had misapprehended the law by concluding that the exacerbation of a pre-existing condition is not compensable under the Tennessee Workers' Compensation Law. The trial court agreed with Dr. Sweo’s opinion that the need for knee replacement surgery was primarily caused by the work accident and ordered the Employer to pay for medical benefits, including the knee replacement surgeries.

On the first appeal to the Workers’ Compensation Appeals Board, the Appeals Board affirmed the trial court’s order that the employer should provide medical treatment for any symptoms related to the accident but reversed the trial court’s order for knee replacement surgeries. The Appeals Board remanded the case back to the trial court.

On remand, both parties retained additional medical experts. The employer hired Dr. Christian Claiborne, who opined that “an aggravation is synonymous with an anatomic change” and that Ms. Edwards had not suffered a permanent anatomic change from the accident. Like Dr. Hutchison, Dr. Claiborne testified that the pre-existing arthritis, not the truck accident, necessitated knee surgery. 

The employee hired Dr. Lawrence Schrader, who opined that Ms. Edwards had sustained an aggravation to her knee arthritis that was more likely than not due to the truck accident. Dr. Schrader testified that Ms. Edwards was asymptomatic prior to the accident and became permanently symptomatic after the accident aggravated her pre-existing arthritis.

The trial court convened another hearing and determined that the opinions of Dr. Sweo and Dr. Schrader were supported by the evidence and again ordered the Employer to pay for bilateral knee replacement surgeries. As part of the trial court’s order, it again stated that Dr. Hutchison had misstated Tennessee law by opining that exacerbations of pre-existing conditions were not compensable. The trial court also stated that Dr. Christian was incorrect when he stated that an aggravation injury required an anatomic change.

On the second appeal to the Appeals Board, two of the three judges determined that Ms. Edwards’ knee surgeries were not compensable. While the majority found that the preponderance of the evidence supported the trial court’s finding that Ms. Edwards had sustained a compensable aggravation of her pre-existing knee arthritis, the evidence did not support a finding that the need for bilateral knee replacements was more than 50% caused by the truck accident. The majority attributed greater weight to the opinions of Dr. Hutchison and Dr. Christian than to the opinions of Dr. Sweo and Dr. Schrader. The dissenting judge disagreed with the majority’s conclusion, reasoning that there was sufficient evidence that the truck accident caused new or increased symptoms that led to functional limitations and the need for knee replacement surgery was hastened by the truck accident.

Employee appealed the Appeals Board’s decision to the Tennessee Supreme Court. The Supreme Court reversed the Appeals Board, finding that the post-reform workers’ compensation statute indicated a change from prior case which required a permanent worsening of a condition before an aggravation was compensable. The Supreme Court clarified that under current law, a compensable aggravation does not require proof of a permanent anatomic change or worsening of the condition.  Instead, a compensable aggravation requires: (1) proof establishing that the work accident contributed more than 50% in causing the aggravation, and (2) proof establishing that the aggravation contributed more than 50% in causing disablement or the need for medical treatment. The Supreme Court held that Ms. Edwards’ proof satisfied both elements and therefore determined that the employer was responsible for the knee surgery.

The Edwards decision represented an important clarification (and some would argue, a drastic change) in the analysis of compensability of aggravation injuries. No longer should we be focused on whether the accident caused an anatomic change to the pre-existing condition, since the Supreme Court determined that such a finding was not necessary. Instead, we should be more focused on the more general questions of whether the work accident was the primary cause of the aggravation, and whether the aggravation was the primary cause of the medical treatment at issue.

For any questions, please contact:
Fredrick R. Baker, Member
Wimberly Lawson Wright Daves & Jones, PLLC
1420 Neal Street, Suite 201
P.O. Box 655
Cookeville, TN 38503-0655
Phone: 931-372-9123
Fax: 931-372-9181
fbaker@wimberlylawson.com
www.wimberlylawson.com