JASON BEDNAR v. MEMORIAL HEALTHCARE SYSTEM D/B/A ) MEMORIAL HOSPITAL, ET AL., AND ) ) TROY HALEY, ADMINISTRATOR OF THE ) BUREAU OF WORKERS’ COMPENSATION ) SUBSEQUENT INJURY AND VOCATIONAL ) RECOVERY FUND - Articles

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JASON BEDNAR v. MEMORIAL HEALTHCARE SYSTEM D/B/A ) MEMORIAL HOSPITAL, ET AL., AND ) ) TROY HALEY, ADMINISTRATOR OF THE ) BUREAU OF WORKERS’ COMPENSATION ) SUBSEQUENT INJURY AND VOCATIONAL ) RECOVERY FUND

Posted by: Azya Thornton on Apr 11, 2025

Court: TN Workers Comp Appeals Board

Attorneys 1: Carmen Y. Ware, Chattanooga, Tennessee, for the employee-appellant, Jason Bednar.

Attorneys 2: C. Douglas Dooley and Mickala J. Lewis, Chattanooga, Tennessee, for the employer- appellee, Memorial Healthcare System d/b/a Memorial Hospital.

Attorneys 3: Patrick Ruth, Nashville, Tennessee, for the appellee, Tennessee Subsequent Injury and Vocational Recovery Fund.

Judge(s): GODKIN

In this appeal, the employee claims he is permanently and totally disabled due to a work incident that caused physical and mental injuries. The employer initially authorized medical treatment but later disputed compensability based primarily on the employee’s preexisting physical and mental conditions. Following the trial, the court concluded that the employee had not met his burden of proof in establishing a compensable physical or mental injury. Specifically, the court determined that because the employee failed to meet his burden of proving a compensable physical injury, he also could not prove that he sustained a compensable mental injury pursuant to Tennessee Code Annotated section 50- 6-102(15). The employee has appealed. Upon careful consideration, we conclude the preponderance of the evidence supports a finding that the employee suffered a compensable temporary aggravation of a preexisting condition, and we therefore reverse the trial court’s finding that the employee did not prove a compensable physical injury. We remand the case for the trial court to address whether, in light of our holding with respect to the employee’s physical injuries, he suffered a compensable mental injury and if so, the extent of the employee’s psychiatric impairment and resulting permanent disability, if any.

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