Tennessee Workers’ Compensation: (1) De Novo Review of Factual Findings Regardless of Deposition vs. Live Proof; (2) “Aggravation” Is Compensable Without Permanent Worsening if Statutory >50% Causation Is Met

Case: Jo Carol Edwards v. Peoplease, LLC, ET AL.
Court: Supreme Court of Tennessee
Date: December 22, 2025
Docket: No. W2024-01034-SC-R3-WC

1. Introduction

This decision resolves two recurring and highly consequential issues in Tennessee workers’ compensation practice after the Workers’ Compensation Reform Act of 2013: (1) how appellate bodies must review factual findings made by the Court of Workers’ Compensation Claims; and (2) when an “aggravation” of a pre-existing condition is compensable under Tenn. Code Ann. § 50-6-102(12).

Parties and dispute. Plaintiff Jo Carol Edwards, a truck driver for Peoplease, LLC, was injured in a work-related crash after a tire blew out, sending the vehicle down an embankment into a bridge. Her knees struck the truck’s interior, and she later sought medical coverage and disability benefits, asserting that the accident aggravated severe, pre-existing knee arthritis and led to bilateral knee replacements and disability. The employer denied compensability for the surgeries and related benefits.

Procedural posture. The Court of Workers’ Compensation Claims awarded benefits, the Workers’ Compensation Appeals Board reversed, and the Tennessee Supreme Court granted review (exercising jurisdiction under Tenn. Sup. Ct. R. 51, § 2).

Key issues. The Court addressed (i) whether the Appeals Board used the wrong review standard when assessing factual findings grounded in deposition medical proof; and (ii) whether “aggravation” requires proof of permanent worsening (or “anatomic change”) to be compensable, and how the statutory “more than 50%” causation requirements apply to aggravation claims.

2. Summary of the Opinion

Disposition. The Court reversed the Appeals Board, reinstating the Trial Court’s December 12, 2023 award of medical coverage and temporary and permanent total disability benefits.

3. Analysis

3.1 Precedents Cited (and How They Shaped the Decision)

A. Standard of Review and Deference: Correcting Drift from Statutory De Novo Review

The Court’s standard-of-review clarification is both statutory and corrective: it restores the primacy of Tenn. Code Ann. § 50-6-225(a)(2) and Tenn. Code Ann. § 50-6-239(c)(7) over “loose language” that had encouraged over-deference.

• Madden v. The Holland Group of Tenn., Inc. (277 S.W.3d 896 (Tenn. 2009)) and Tyron v. Saturn Corp. (254 S.W.3d 321 (Tenn. 2008))
  The Court identifies Madden as a source of confusion because it described “considerable deference” to trial-court factual determinations and cited Tyron. The Court emphasizes that Tyron did not create broad deference to factual findings; it afforded deference only to credibility and weight assessments tied to in-court testimony. The opinion instructs that Madden’s expansive deference language “is incorrect and should no longer be followed,” realigning review practice with the statute.
• Kilburn v. Granite State Ins. (522 S.W.3d 384 (Tenn. 2017)) and Jumper v. Kellogg Co. (No. W2020-01274-SC-R3-WC, 2021 WL 2582178 (Tenn. Workers’ Comp. Panel June 23, 2021))
  These decisions are cited as examples of panels giving “considerable deference” when trial judges observed witnesses. Edwards narrows that principle: deference is appropriate for live-witness credibility determinations, but it does not convert the statutory de novo review of factual findings into an abuse-of-discretion standard.
• Moore v. Beacon Transportation, LLC (No. 2018-06-1503, 2021 WL 5105749 (Tenn. Workers’ Comp. App. Bd. Oct. 29, 2021))
  Moore is used to illustrate institutional inconsistency within the Appeals Board. The Edwards Court intervenes to end the split, explicitly answering whether appellate panels must review documentary medical proof de novo (with presumption of correctness for factual findings) rather than for abuse of discretion.
• Lytle v. Fru-Con, Inc. (No. W2002-01337-WC-R3-CV, 2003 WL 213775 (Special Workers’ Comp. Panel Jan. 30, 2003)) and Wingert v. Gov't of Sumner Cnty. (908 S.W.2d 921 (Tenn. 1995))
  These authorities are invoked for the functional meaning of statutory “de novo upon the record”: an independent examination of the record to determine where the preponderance lies.
• Dyson-Kissner-Moran Corp. v. Shavers (No. E2015-02005-SC-R3-WC-MAILED, 2015 WL 12850553 (Special Workers’ Comp. Panel Dec. 16, 2015)), Wells v. Tenn. Bd. of Regents (9 S.W.3d 779 (Tenn. 1999)), Woodlawn Mem'l Park, Inc. v. Keith (70 S.W.3d 691 (Tenn. 2002)), Tobitt v. Bridgestone/Firestone, Inc. (59 S.W.3d 57 (Tenn. 2001)), Krick v. City of Lawrenceburg (945 S.W.2d 709 (Tenn. 1997)), Humphrey v. David Witherspoon, Inc. (734 S.W.2d 315 (Tenn. 1987)), and Goodwin v. Jim Bale Constr., LLC (No. M2014-00919-COA-R3-CV, 2015 WL 3814163 (Tenn. Ct. App. June 18, 2015))
  Together, these cases establish and reinforce the credibility-review distinction that becomes central to Edwards’ correction: live-witness credibility determinations warrant deference (abuse-of-discretion review), because the trial judge sees demeanor. Edwards uses them to justify limited deference—without letting that limited deference swallow the statutory de novo review rule.
• Richards v. Liberty Mut. Ins. Co. (70 S.W.3d 729 (Tenn. 2002)), Houser v. Bi-Lo, Inc. (36 S.W.3d 68 (Tenn. 2001)), Orman v. Williams Sonoma, Inc. (803 S.W.2d 672 (Tenn. 1991))
  These precedents supply the key documentary-proof principle: when medical proof is by deposition, the reviewing court is in the same position as the trial court to assess weight and credibility, so it may draw its own conclusions. Edwards relies on this line to reject the Appeals Board’s use of abuse-of-discretion review for deposition-based medical proof.
• Bowman v. Bowman (836 S.W.2d 563 (Tenn. Ct. App. 1991)) and Early v. Street (241 S.W.2d 531 (Tenn. 1951))
  Cited for the general civil principle that credibility is for the trial court that “saw and heard” witnesses—again, supporting Edwards’ careful separation of (a) deference to live credibility findings from (b) de novo review of the remainder of factual findings.

B. Aggravation After the 2013 Reform: Moving from Common-Law Tests to Statutory Causation

• Miller v. Lowe's Home Ctrs., Inc. (No. 2015-05-0158, 2015 WL 6446638 (Tenn. Workers' Comp. App. Bd. Oct. 21, 2015))
  Miller is used to explain what the 2013 Reform Act changed: it rejected liberal construction, demanded “fair and impartial” construction, required a specific incident, and heightened causation to “contributed more than 50%,” replacing the older “could be” causation approach. Edwards leans on Miller to frame aggravation claims as statutory causation problems rather than common-law categories.
• Trosper v. Armstrong Wood Prods., Inc. (273 S.W.3d 598 (Tenn. 2008))
  Trosper supplied the pre-2013 common-law description of compensable aggravation (advance severity or new distinct injury beyond increased pain). Edwards holds that because the 2013 Reform Act now defines “injury” to include aggravation in statutory text, Trosper’s explanation “and its progeny are inapposite” for post-July 1, 2014 injuries.
• Paris v. McKee Foods Corp. (No. E2020-00358-SC-R3-WC, 2021 WL 668493 (Tenn. Workers' Comp. Special Panel Feb. 16, 2021))
  Paris is cited as an example of courts conflating Trosper’s “new injury” language with an “anatomic change” requirement. Edwards rejects an anatomic-change prerequisite as inconsistent with the statute’s text and ordinary meaning.
• Edwards-Bradford v. Kellogg Co. (2023 WL 5704526 (Tenn. Workers' Comp. Panel Sept. 5, 2023)) and Shelton v. Hobbs Enters., LLC (No. M2020-01220-SC-R3-WC, 2021 WL 4432624 (Tenn. Workers' Comp. Panel Sept. 27, 2021))
  The Court notes that the Special Workers’ Compensation Appeals Panel has discussed aggravation post-2013 “albeit tangentially,” underscoring that the Supreme Court itself had not squarely addressed post-Reform aggravation compensability until Edwards.
• Brookside Mills, Inc. v. Atkins (322 S.W.2d 217 (Tenn. 1959)), State v. Deberry (651 S.W.3d 918 (Tenn. 2022)), Ellithorpe v. Weismark (479 S.W.3d 818 (Tenn. 2015)), State v. Edmondson (231 S.W.3d 925 (Tenn. 2007)), State v. Robinson (676 S.W.3d 580 (Tenn. 2023)), State v. Cauthern (967 S.W.2d 726 (Tenn. 1998))
  These interpretive decisions guide the Court’s textual method for defining “aggravation” without a statutory definition: use ordinary meaning, dictionary definitions near enactment, and read text in context without forced construction. This methodology leads to a definition of aggravation that does not require permanence.
• Coffey v. City of Knoxville (866 S.W.2d 516 (Tenn. Workers' Comp. Panel 1993))
  Coffey supports the Court’s evidentiary boundary: physicians may provide medical opinions, but not legal conclusions (such as whether an injury is “compensable”). Edwards uses this to discount testimony from Drs. Hutchison and Christian insofar as it offered “not compensable” conclusions grounded in incorrect legal premises.

3.2 Legal Reasoning

A. The Standard of Review: Statute First, With Properly Cabined Deference

Edwards builds a clean, two-track review model that aligns practice with statute and with long-standing credibility doctrine:

• Track 1 — Factual findings: Review is de novo on the record with a presumption of correctness, displaced when the evidence preponderates otherwise (Tenn. Code Ann. § 50-6-225(a)(2); Tenn. Code Ann. § 50-6-239(c)(7)).
• Track 2 — Credibility determinations:
  • Live testimony: abuse-of-discretion review (trial judge saw demeanor).
  • Depositions: no deference (appellate tribunal reads what the trial judge read).

The Court’s practical correction is aimed at the Appeals Board’s specific error: it applied an abuse-of-discretion standard to deposition-based medical proof. Both parties conceded the error, and the Court agreed, invoking Richards v. Liberty Mut. Ins. Co. and related precedents to hold that documentary medical proof cannot justify that level of deference.

B. Defining “Aggravation” Under Tenn. Code Ann. § 50-6-102(12)

The Court rejects attempts to import permanence and “anatomic change” into the statute. Its reasoning proceeds in three steps:

1. Textual anchor: The 2013 Reform Act expressly addresses aggravation: an “injury” excludes aggravation of a preexisting condition unless it is shown to a reasonable degree of medical certainty that it “arose primarily” out of and in the course and scope of employment (Tenn. Code Ann. § 50-6-102(12)(A)).
2. Ordinary meaning: Because “aggravation” is undefined, the Court looks to ordinary meaning and dictionary usage, concluding it is an intensification or worsening and “does not require a permanent change or a permanent worsening.”
3. Contextual fit with statutory structure: The statute contemplates compensable injuries that cause “the need for medical treatment,” which can include treatment that resolves the aggravation. That structure is inconsistent with a permanence prerequisite.

C. The Two Causation Gates for Aggravation Claims (and How Edwards Applies Them)

Edwards’ most operational contribution is its stepwise application of the statute’s causation requirements to aggravation:

1. Gate 1 (arising primarily): The employee must show employment contributed more than 50% in causing the aggravation (Tenn. Code Ann. § 50-6-102(12)(B)), supported by “reasonable degree of medical certainty” as defined in § 50-6-102(12)(D).
2. Gate 2 (resulting harm): The employee must show the aggravation contributed more than 50% in causing death, disablement, or the need for medical treatment (Tenn. Code Ann. § 50-6-102(12)(C)).

Application to Edwards’ facts. The Court treated the first gate as satisfied—consistent with both lower tribunals— because all physicians recognized increased symptoms and decreased function after the accident. The contested question was the second gate: whether the aggravation (not merely the underlying arthritis) was more than 50% responsible for the need for surgery and disability.

The Court upheld the Trial Court’s conclusion for several linked reasons grounded in record evaluation and proper legal framing:

• Eligibility-for-surgery logic tied to symptom onset: The opinion reasons that if Ms. Edwards was asymptomatic before, doctors would not typically recommend knee replacement; she became symptomatic after the accident. Therefore, the aggravation “caused the need for knee replacement surgery” in the statutory sense—because it was the causal driver of the disabling symptoms and functional limits that led to the treatment.
• Presumption for treating physician was rebutted: Although Tenn. Code Ann. § 50-6-102(12)(E) affords presumptive correctness to the treating physician selected from the employer panel (here, Dr. Hutchison), the Court held the record “preponderates against” that presumption.
• Medical opinions discounted when built on legal error: Dr. Hutchison’s and Dr. Christian’s “not compensable” conclusions were treated as impermissible legal conclusions (Coffey v. City of Knoxville) and, substantively, as reflecting incorrect legal premises (permanence/anatomic change as requirements).
• Proper role of lay testimony and trial-court observation: The Trial Court found Ms. Edwards credible, observed her limp and cane use, and credited her testimony that she had no knee pain before the accident. Edwards’ review framework preserves appropriate deference to that live-witness credibility determination while independently assessing deposition medical proof.

D. Disability Benefits

Having found the aggravation compensable and causally linked to surgery and disablement, the Court reinstated both:

• Temporary total disability benefits: Supported by work restrictions and an end date tied to “maximum medical improvement” as discussed with reference to Tenn. Code Ann. § 50-6-207(1)(E).
• Permanent total disability benefits: The Court accepted the Trial Court’s reliance on Dr. Schrader’s permanent limitations, rejecting the Appeals Board’s view that they were fatally attributable to non-compensable injuries; the Court concluded the knee aggravation stemming from the accident supported permanent total disability.

3.3 Impact

A. Institutional Impact: Appeals Board and Panel Review Will Shift

Edwards is likely to recalibrate appellate behavior in workers’ compensation cases by eliminating a shortcut that had developed: characterizing deposition-driven factual determinations as discretionary calls. The decision directs that appellate panels must do what the statute says—independently examine the record—and cannot invoke abuse-of-discretion review to affirm or reverse deposition-based medical proof assessments.

B. Substantive Impact: Aggravation Claims Become Statutory-Causation Cases, Not “Permanent Change” Debates

By rejecting permanence/anatomic-change prerequisites, Edwards redirects litigants and tribunals toward the two statutory causation gates. The most significant practical effects include:

• Reduced reliance on “anatomic change” rhetoric: Defense experts who frame non-compensability around lack of permanent structural change may be less persuasive because the Court declares that is not the statutory test.
• Greater emphasis on symptom onset and functional change: For degenerative conditions (like arthritis) where imaging may predate symptoms, the timing and trajectory of symptoms and functional limits become pivotal to proving that the aggravation (not merely the preexisting disease) was >50% responsible for the medical treatment/disability.
• Treating physician presumption remains important but more contestable: Edwards demonstrates that the § 50-6-102(12)(E) presumption can be overcome where the treating physician’s causation opinion rests on an incorrect understanding of Tennessee law or unsupported assumptions contradicted by the broader record.

4. Complex Concepts Simplified

• “De novo on the record with a presumption of correctness”: The reviewing court re-reads the record for itself (“de novo”), but starts by assuming the trial court’s factual finding is correct. If the record shows the other side’s evidence is more convincing overall (“preponderates otherwise”), the reviewing court may change the finding.
• “Abuse of discretion” (credibility only): A high-deference standard. Edwards confines it mainly to credibility calls based on live testimony—because only the trial judge saw the witness’s demeanor.
• “Reasonable degree of medical certainty” (Tenn. Code Ann. § 50-6-102(12)(D)): The physician’s opinion that something is “more likely than not,” considering all causes—not mere possibility.
• The “more than 50%” causation requirement: After the 2013 Reform Act, it is not enough that work was one cause among many. Work must contribute more than half of the causal explanation for (1) the aggravation itself, and (2) the resulting need for treatment/disability.
• “Aggravation” vs. “pre-existing condition”: The pre-existing condition is the underlying disease (here, arthritis). The aggravation is what the accident does to it—making it worse or intensifying symptoms. Edwards holds that aggravation can be compensable even if it is not a permanent anatomical worsening, so long as the statutory causation thresholds are met.
• Treating physician “presumed correct” (Tenn. Code Ann. § 50-6-102(12)(E)): The employer-panel treating physician’s causation opinion starts with extra weight, but the employee can overcome it by a preponderance of the evidence.

5. Conclusion

Jo Carol Edwards v. Peoplease, LLC delivers two major clarifications in Tennessee workers’ compensation law.

• First, it restores the statutory review framework: factual findings are reviewed de novo on the record with a presumption of correctness, and deposition-based medical proof does not trigger abuse-of-discretion deference.
• Second, it clarifies post-2013 aggravation law: “aggravation” does not require permanent worsening or an anatomic change; compensability turns on the statute’s two >50% causation requirements, proven to a reasonable degree of medical certainty.

Applying these principles, the Court held the employee rebutted the treating-physician presumption, proved that the work-related crash aggravated her arthritis in a compensable way, and proved that the aggravation was more than 50% responsible for the need for knee replacements and resulting disability—thereby reinstating the Trial Court’s award.