The Court of Appeals affirmed dismissal of a personal injury case because the defendant qualified as a statutory employer of plaintiff under Tennessee’s workers’ compensation laws. Under the “exclusivity doctrine” in worker’s compensation law, an employee cannot sue his or her employer under tort law. Instead, the exclusive remedy for the employee is under worker’s compensation law.
In Coblentz v. Tractor Supply Company, No. M2023-00249-COA-R3-CV (Tenn. Ct. App. Apr. 26, 2024), plaintiff worked as a sales representative for a hardware company. The hardware company supplied certain products to defendant retail store. Plaintiff’s job therefore included visiting defendant store, along with many other stores, to check its inventory. While at the store, plaintiff would determine whether additional inventory from his hardware company should be sent, stock any new product, and generally straighten the area where his company’s products were displayed. Plaintiff typically visited defendant store every four to six weeks.
During one visit, a large barn door fell off its track and hit plaintiff. Plaintiff filed a workers’ compensation case against the hardware company he worked for, which was settled. He also filed this personal injury case against defendant retail store. Defendant moved for summary judgment, arguing that it was a statutory employer under Tennessee’s workers’ compensation laws, and that workers’ compensation was therefore plaintiff’s exclusive remedy. The trial court agreed, granting summary judgment to defendant, and the Court of Appeals affirmed.
