Opinion

Lella Yvonne Graham v. CHI Memorial Healthcare System

Court
Tennessee Supreme Court
Filed
Nov 20, 2025
Status
Published
Cited by
0 cases
Authority
More cited than 37.5%

The opinion

IN THE SUPREME COURT OF TENNESSEE

SPECIAL WORKERS’ COMPENSATION APPEALS PANEL

AT KNOXVILLE

Assigned on Briefs July 16, 2025

LELLA YVONNE GRAHAM Vv. CHI MEMORIAL HEALTHCARE

SYSTEM, ET AL.

Appeal from the Workers’ Compensation Appeals Board FILED

Court of Workers’ Compensation Claims, No. 2021-01-0857

Thomas L. Wyatt, Judge NOV 26 2025

Clork of theyppetfate Coprts

REC'd By -.

No. E2024-01928-SC-R3-WC Mailed September 3, 2025

This appeal involves an employee’s claim for workers’ compensation

benefits relating to her alleged contraction of the COVID-19 virus at

work. The appeal has been referred to the Special Workers’

Compensation Appeals Panel for a hearing and a report of findings of fact

and conclusions of law pursuant to Tennessee Supreme Court Rule 51.

We affirm the judgment of the Appeals Board and adopt its opinion as set

forth in the attached Appendix.

Tenn. Code Ann. § 50-6-217(a)(2)(B) Appeal as of Right;

Decision of the Workers’ Compensation Appeals Board Affirmed

W. MARK WARD, J., delivered the opinion of the court, in which DWIGHT E. TARWATER,

J. and Roy B. MORGAN, JR., J., joined.

Jimmy W. Bilbo, Cleveland, Tennessee for the Appellant, Lella Yvonne Graham

C. Douglas Dooley & Mickala Lewis, Chattanooga, Tennessee for the Appellee, CHI

Memorial Healthcare System

OPINION

Lella Yvonne Graham worked at a medical facility in Cleveland, Tennessee,

operated by CHI Memorial Healthcare System. Graham alleges that she contracted

COVID-19 in December 2020 due to regular contact with clinic patients and

coworkers infected with the virus. She further alleges that she has suffered a

disabling lung injury and other “long COVID” complications because of the illness.

CHI Memorial initially paid temporary disability benefits to Graham for a

short period. After conducting an investigation, however, CHI Memorial denied

Graham’s request for total disability benefits based on its determination that

Graham’s alleged injuries were not compensable.

CHI Memorial based its position on medical opinions provided by Dr.

Michael Czarnecki, a board-certified pulmonologist. Dr. Czarnecki found that

Graham had widespread community-risk exposure to COVID-19 and opined that it

was not medically possible to conclude that her exposure at work primarily caused

her to contract the virus. In other words, Graham could not show that her alleged

injuries arose primarily out of and in the course of her employment, as Tennessee

Code Annotated section 50-6-102(12) requires.

Relying on Dr. Czarnecki’s opinion, CHI Memorial filed a motion for

summary judgment. The Court of Workers’ Compensation Claims set the motion

for a hearing on July 16, 2024.

On July 3, 2024, Graham filed a motion for continuance of the summary

judgment hearing. Graham argued that she had retained an expert to provide a

medical-causation opinion to support her claims, but that he failed to do so. She

argued that she needed more time to obtain a new medical expert. CHI Memorial

opposed the requested continuance, arguing that Graham had ample time to obtain

medical proof.

The Court of Workers’ Compensation Claims denied Graham’s motion for a

continuance in an order dated July 12, 2024. Graham did not immediately appeal

that order. Subsequently, on July 23, 2024, the court granted CHI Memorial’s

motion for summary judgment and entered judgment in its favor. The court

accredited Dr. Czarnecki’s opinion that Graham could not establish medical

causation and concluded that summary judgment was warranted because Graham

failed to introduce any expert medical proof to support her claim. Graham filed a

notice of appeal on August 21, 2024.

A unanimous Appeals Board rejected both issues that Graham presented on

appeal. First, the Appeals Board dismissed as untimely Graham’s attempt to appeal

the trial court’s interlocutory order denying her request for continuance of the

summary judgment hearing. Second, the Appeals Board affirmed the trial court’s

summary judgment given Graham’s failure to introduce any expert medical

causation evidence supporting her claim.

Graham raises the same two issues in this appeal. Upon due consideration,

we affirm the judgment of the Appeals Board and adopt its opinion as set forth in

the attached Appendix.

CONCLUSION

The decision of the Workers’ Compensation Appeals Board is affirmed.

Costs of this appeal are taxed to Lella Yvonne Graham, for which execution may

issue.

S: W. Mark Ward

W. MARK WARD, SENIOR JUDGE

APPENDIX

(OPINION OF THE WORKERS’ COMPENSATION

APPEALS BOARD)

Factual and Procedural Background

Lella Yvonne Graham (“Employee”), a practice manager at CHI Memorial

Healthcare System’s (“Employer”) Cleveland, Tennessee facility, alleges that she

contracted COVID-19 in the course of performing her job duties in December 2020.!

1 In her petition, Employee asserts she was tested for COVID-19 on December 13, 2020, and was

diagnosed on December 14, 2020. Employee then filed an amended PBD on December 14, 2021,

asserting a date of injury of December 12, 2020.

A

Specifically, Employee contends she became sick due to regular contact with

coworkers and patients infected with COVID-19 at Employer’s facility. Employee

filed a Petition for Benefit Determination (“PBD”) on December 13, 2021, in which

she asserted that she suffered an injury to her lungs due to contracting COVID-19 in

mid-December 2020. In the PBD, Employee noted that she reported the incident to

Employer on December 13, 2020, and saw a nurse practitioner at CHI Memorial

Convenient Care later that same day. In the medical note for that encounter, the nurse

practitioner noted that Employee’s tests for Flu B and COVID-19 were both positive.

Employee was treated conservatively and released. On December 17, 2020,

Employee was seen in the emergency department of CHI Memorial Hospital for

complaints of shortness of breath, headache, and “[COVID- 19] type symptoms . . .

with positive results for [COVID-19].” Employee was admitted and diagnosed with

hypoxia and COVID-19., She was discharged on January 2, 2021.

. Thereafter, Employee had a telehealth appointment with Madeline

Grotefendt, FNP-C, at CHI Memorial Primary Care Associates — Cleveland

(“CMPCA-C”). The medical note for that virtual visit states Employee “was

admitted to CHI Memorial Hospital with viral pneumonia due to COVID-19, acute

respiratory failure with hypoxia, and influenza.” The note also indicated that

Employee needed post-hospital care, including physical therapy and pulmonary

rehabilitation, for which she received a referral. Ms. Grotefendt continued

conservative treatment and instructed Employee to follow up in one month.

Employee returned on February 8, 2021, with complaints of “significant weakness.”

Ms. Grotefendt noted that Employee appeared “fatigued” and still required

supplemental oxygen therapy.

During her subsequent deposition, Employee recounted that Ms. Grotefendt

imposed restrictions limiting how frequently and how long she could work once she

was able to return to work in some capacity. The work release signed by Ms.

Grotefendt provided Employee could “[rJeturn to work for 4 hours a day on Monday,

Wednesday, and Friday beginning on 4-5-21. Ifable to tolerate this work schedule[,]

then [Employee] may work 4 hours daily Monday through Fridays beginning

4/12/21[.]” Employee’s condition failed to improve, and she returned to CMPCA-C

on eleven subsequent occasions between March 2021 and November 2023.

Ultimately, Ms. Grotefendt referred Employee to Dr. Michael T. Czarnecki, a

pulmonologist affiliated with Pulmonary & Critical Care Consultants of

Chattanooga, for further evaluation.

Dr. Czarnecki performed a medical examination of Employee at Employer’s

request on April 3, 2023. In the medical report electronically signed on April 4, Dr.

3 da

Czarnecki acknowledged that Employee “had a broad community relative risk

exposure” to COVID-19 and post COVID-19 complications, but he opined that the

correlation of her exposure due to patient care does not necessarily translate to

causation of those conditions. He further stated that her “absolute risk is the same as

anyone else interacting on a day-to-day basis at work or outside of work.” Dr.

Czarnacki summed up his opinion by stating that it was not possible to draw a

conclusion regarding the connection between Employee’s work and her contracting

COVID-19 and that, therefore, Employee was not entitled to any permanent

impairment as a result of her alleged work exposure to COVID-19.

Additionally, Dr. Czarnecki opined that Employee was at maximum medical

improvement but expressed his concern that Employee had not undergone

pulmonary function testing, which would be essential to determining the degree of

residual pulmonary impairment. Finally, Dr. Czarnecki assessed an anatomical

impairment rating of forty percent for “[COVID-19] related organ dysfunction

impairment.”

The parties deposed Dr. Czarnecki on May 21, 2024. In response to a question

from counsel regarding whether it was his opinion that the assessment of a zero-

percent impairment “was a result of [Employee’s] employment,” Dr. Czarnecki

stated:

A. That is correct in the first component of causality. It was hard to

determine, you know, like I said with the community pulmonary

[COVID-19]-related pandemic. There’s no way to determine

that.

Q. And is that your opinion within a reasonable degree of medical

certainty?

A. Yes.

Q. Within the concept of broad community relative risk exposure,

is it impossible to determine when or how there was a [COVID-

19] exposure and subsequent contraction of [COVID-19]?

A. Well, that’s the million dollar question. Yes, it is.

On cross-examination, Dr. Czarnecki was asked if there is “a difference

between an impairment rating and [a] disability.” Dr. Czarnecki responded in the

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affirmative, stating it “depends on what the disability is for and who did the

disability. .. . I believe there’s a difference between disability and impairment from

my perspective. A pulmonary impairment is different from a disability.” Finally,

counsel for Employee asked Dr. Czarnecki whether “it’s more likely than not that

[Employee] contracted [COVID-19] at work,” to which Dr. Czarnecki responded

that making such an assessment required an examination of multiple factors. He

further stated:

[E]ven if you were hermetically sealed, it’s nearly impossible to avoid

exposure from infectious diseases, right? There’s going to be some

airborne-related exposure just living in a house even if you never left

your house. There has to be — the standard of perfection has to be so

high that you just can’t — even if you did achieve it, you’re still going

to have exposure. So[,] | don’t think you can make the argument that

the only place the exposure occurred in my opinion was at the

workplace exclusively. And that’s what we documented in there in

terms of the work-related exposure is zero percent.

So[,] 1 think we would stand by our report where we say a rating of zero

percent would be given to [Employee’s] employment as contributing to

the cause of her injury in our opinion. . . . Even direct patient care does

not necessarily imply causation. The absolute risk is the same as anyone

else interacting on a day-to-day basis at work or outside of work and,

you know, including never leaving the house. So[,] I don’t think — you

know, I would stand by what I document there.

Employee later filed another PBD in July 2022, which indicated that

Employee was released to work on May 3, 2021, and had been assigned an

impairment rating of 70% to the body as a whole by Dr. Jeffrey Jump, a general

practitioner. In July 2023, a mediator issued a dispute certification notice that

certified compensability, medical benefits, and temporary and permanent disability

benefits as the issues in dispute. It also identified the “Injature and extent of [the]

injury” as the defense raised by Employer.

Thereafter, Employer filed four motions with the trial court: (1) a motion for

summary judgment; (2) a motion to dismiss Employee’s original and amended

PBDs, which was later withdrawn; (3) a motion in limine to exclude the lay

testimony of Employee as it relates to medical causation; and (4) a second motion in

_6-

limine to exclude the Form C-30A completed by Dr. Jump. The trial court heard both

motions in limine telephonically, and, two days later, entered an order granting

Employer’s motion to exclude Employee’s lay testimony regarding medical

causation and “strik[ing] the [Form C-30A] signed by Dr. Jump as inadmissible

hearsay.”* Contemporaneous with its June 26 order resolving Employer’s motions

in limine, the trial court issued an order setting Employer’s motion for summary

judgment for a telephonic hearing on July 16, 2024.3 In the interim, Employee filed

a motion for a continuance of the summary judgment hearing, which Employer

opposed. In that motion, Employee contended her counsel paid the fee for Dr. Jump

to complete a Form C-32 in February 2022, but that Dr. Jump did not notify counsel

he would not complete the Form C-32 until May 2024. Employee submitted that she

had made multiple attempts to find an expert since that time and was unsuccessful,

but finally secured an appointment with a pulmonologist on July 11, 2024. Employer

opposed that motion on the grounds that the scheduling order had previously been

modified and Employee had ample time to obtain her medical proof. The trial court

denied the motion for continuance in an order dated July 12, 2024. That order was

not appealed.

At the July 16 hearing on Employer’s motion for summary judgment, the trial

court considered the expert opinion of Dr. Czarnecki and reviewed the medical

evidence introduced by Employer. In the compensation order issued on July 23,

2024, the court noted Dr. Czarnecki was board-certified in pulmonology, internal,

and critical-care medicine and had examined Employee once to date. In accrediting

Dr. Czarnecki’s causation opinion finding that Employee’s “work in a clinic treating

[COVID-19] patients had ‘zero percent’ causal relationship with her own infection,”

and given that Employee “offered no expert testimony to dispute this opinion,” the

trial court determined that Employer had “negated the essential element of [medical]

causation” and, thus, was entitled to summary judgment as a matter of law.

Continuing further, the court observed that Employee’s “sworn statement that she

contracted the virus while working in a facility treating patients with [COVID-19]

does not, standing alone, place the pulmonologist’s opinion in dispute.”

Accordingly, the trial court entered judgment in favor of Employer and dismissed

Employee’s claim with prejudice. Employee has appealed.

2 In its order, the trial court stated Employee “did not timely respond to the motions in limine” and “[t]he

court file in this case did not contain a response filed by [Employee] at the time of the entry of this order.”

Further, unlike a Standard Form Medical Report (Form C-32), there is no statute or regulation rendering a

Form C-30A admissible at the summary judgment stage.

3 Defendant’s motion did not include a hearing date on the face of it, as required by Tenn. Comp. R. and

Regs. 0800-02-21-.18(c).

Standard of Review

The grant or denial of a motion for summary judgment is a matter of law that

we review de novo with no presumption that the trial court’s conclusions are correct.

See Rye v. Women’s Care Ctr. of Memphis, MPLLC, 477 S.W.3d 235, 250 (Tenn.

2015). As such, we must “make a fresh determination of whether the requirements

of Rule 56 of the Tennessee Rules of Civil Procedure have been satisfied.” Jd.

Moreover, a trial court has broad discretion to control the pace of litigation and set

hearings to address pre-trial motions. Valladares v. Transco Products, Inc., Nos.

2015-01-0117 & -0118, 2016 TN Wrk. Comp. App. Bd. LEXIS 31, at *26 (Tenn.

Workers’ Comp. App. Bd. July 27, 2016) (“a trial court has the necessary discretion

to control the pace of litigation through the use of case supervision and docket

management”); see also Smith v, Smith, No. E2017-01295-COA-R3-CV, 2019

Tenn. App. LEXIS 59, at *20 (Tenn. Ct. App. Jan. 31, 2019) (“trial courts have broad

discretion to control their dockets”), We are also mindful of our obligation to

construe the workers’ compensation statutes “fairly, impartially, and in accordance

with basic principles of statutory construction” and in a way that does not favor

either the employee or the employer. Tenn. Code Ann. § 50-6-116 (2023).

Analysis

In her notice of appeal, Employee contends the trial court erred in denying her

motion for a continuance of the hearing on Employer’s motion for summary

judgment. In addition, Employee argues that the trial court erred in granting

summary judgment under circumstances where Employer failed to file a Notice of

Controversy after suspending benefits pursuant to Tennessee Code Annotated

section 50-6-205(c)-(d).

Employee's Motion for Continuance

Employee argues it was reversible error to deny her motion to continue since

she filed a Rule 72 declaration “providing facts outlining the reasons she could not

present an affidavit in opposition” to Employer's medical expert in time. In doing

so, she relies on Rule 56.07 of the Tennessee Rules of Civil Procedure, which

provides:

Should it appear from the affidavits of a party opposing the motion that

such party cannot for reasons stated present by affidavit facts essential

to justify the opposition, the court may refuse the application for

judgment or may order a continuance to permit affidavits to be obtained

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or depositions to be taken or discovery to be had or make such other

order as is just.

(Emphasis added.) In response, Employer argues the trial court did not abuse its

discretion. We conclude, however, that it is unnecessary for us to address the issue

because it was not timely appealed. The interlocutory order denying Employee’s

motion for a continuance was entered on July 12, 2024, and the issue was first raised

on appeal in the August 21, 2024 notice of appeal. Employee had seven business

days, or until July 23, 2024, to appeal the court’s July 12 order, but she did not.do

so. Thus, we have no jurisdiction to consider this issue. See Tenn. Comp. R. & Regs.

0800-02-22-.01(3) (2023); see also Bates v. Command Ctr., Inc., No. 2014-06-0053,

2015 TN Wrk. Comp. App. Bd. LEXIS 10, at *5 (Tenn. Workers’ Comp. App. Bd.

Apr. 2, 2015) (“Appellate courts treat the untimely filing of a notice of appeal in

civil cases as a jurisdictional defect, resulting in a dismissal of the appeal.”’).

Summary Judgment

Next, Employee argues the trial court erred in granting summary judgment

under circumstances where Employer failed to file a Notice of Controversy after

deciding to suspend benefits as stated in Tennessee Code Annotated section 50-6-

205(c)-(d). Thus, she contends the issue before us is whether an employer’s

purported failure to comply with section 205(c)-(d) “precludes it from now

contending that the accident and the resulting injury to the employee were not within

the coverage of workers’ compensation statutes.” Employer asserts the trial court

correctly granted its motion because, at the summary judgment stage, “Employee

admitted she had no evidence to establish medical causation, despite having over

two years to obtain such proof.”

In its order, the trial court noted that Employee’s Rule 72 declaration did not

include any reference to Employer’s failure to file notices of denial, controversy, or

a change of benefits. The court concluded Employee “presented no sworn evidence

of the alleged filing deficiencies,” noting she mentioned them “in argument in a

response to summary judgment” but did not testify about them in her sworn

declaration. The court also noted Employee cited no statutory or case law in support

of her argument that Employer’s alleged failure to file the required forms precluded

Employer from prevailing on its motion for summary judgment.

In her brief on appeal, Employee relies on Goins v. Kaiser-Roth Hosiery, Inc.,

751 §.W.2d 423 (Tenn. 1988), a Supreme Court case in which the Court determined

the employer’s failure to timely file a notice of controversy precluded it from later

-9-

contending the accident and injury were not compensable. In Goins, the employee

slipped and fell on an “oily looking substance” inside the employer’s plant while on

the way to her workstation before her scheduled shift. Jd. at 424. The incident was

reported immediately and accepted as compensable, and the employer provided both

medical and temporary disability benefits. /d. In fact, the Supreme Court specifically

noted that the “case was accepted by the employer as fully compensable.” /d. At no

point prior to the filing of the complaint did the employer indicate it was reversing

its compensability decision or file the appropriate administrative form as described

in Tennessee Code Annotated section 50-6-205(d) indicating a controversy in the

case or a change or termination of benefits. Jd. Nevertheless, in an answer filed

approximately three months later, the employer challenged compensability,

asserting as an affirmative defense that the incident occurred before the employee

had begun her shift. /d. In rejecting the employer’s effort to deny the compensability

of the claim and affirming the award of benefits, the Tennessee Supreme Court first

noted that the preponderance of the evidence presented during trial supported the

court’s compensability decision irrespective of the employer’s failure to file a notice

of controversy. Id. Second, the Court noted that the “failure of the employer to show

compliance with the statutory requirement [set out in Tennessee Code Annotated

section 50-6-205(d)] . . . precludes it from now contending that the accident and the

resulting injury to the employer were not within the coverage of the workers’

compensation statutes.” Id.

We conclude Employee’s reliance on Goins is misplaced. First, although

Employer in the present case apparently provided certain benefits as contemplated

in the Workers’ Compensation Law when the claim was initially reported, Dr.

Czarnecki expressed his opinion that Employee’s condition could not be traced to

her employment within a reasonable degree of medical certainty in April 2023.

Moreover, the Dispute Certification Notice issued on July 31, 2023, which was

eleven months before Employer filed its motion for summary judgment, listed

“compensability” as a disputed issue.’ Thus, Employee cannot reasonably assert that

it was unaware of Employer’s compensability defense in a timely manner.

Second, the administrative form that existed when Goins was decided, the

Notice of Controversy, is no longer in use as of October 2020. Thus, when Employee

was diagnosed in December 2020, there was no requirement that an employer file a

“notice of controversy” form. Instead, Rule 0800-02-14-.04(8) now requires an

4 Asa result of the passage of the 2013 Workers’ Compensation Reform Act (“Reform Act”), the Dispute

Certification Notice is now used to certify disputed issues to be presented to a trial court for resolution.

That document was not in use when Goins was decided in 1988.

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“adjusting entity” to electronically file a notice of full or partial denial of the claim

“within fifteen (15) calendar days of the due date of the first omitted payment.” Here,

the record is silent regarding when benefits were paid and/or when the “first omitted

payment” allegedly occurred. Thus, there is no evidence in this record that Employer

failed to electronically file a notice of full or partial denial of the claim within the

required time period.

Third, we interpret the Court’s holding on this issue in Goins as a form of

estoppel. Although we acknowledge that the Court did not use that term, it explained

its rationale by clarifying that the employer’s failure to comply with statutory filing

requirements “precluded” it from relying on a compensability defense in

circumstances where it had accepted the claim as “fully compensable” even though

the facts that later formed the basis of its affirmative defense were apparent from the

date of the incident. Jd The implication of the Court’s rationale was that an

employee may detrimentally rely on the employer’s acceptance of the claim and, in

the particular circumstances presented in Goins, the employer should be estopped

from later challenging compensability. However, application of an estoppel theory

is a fact-intensive determination. See, e.g., Nicholson v. Wal-Mart Stores, Inc., No.

M1999-01137-WC-R3-CV, 2001 Tenn. LEXIS 31 (Tenn. Workers’ Comp. Panel

Jan. 12, 2001) (“If the facts justify it, courts will not hesitate to invoke the doctrine

of equitable estoppel . .. . Negligent silence may work an equitable estoppel, and

acts or conduct which are calculated to mislead, and do mislead, will work an

equitable estoppel even when there is no intention to do so.”). Here, as noted above,

Dr. Czarnecki expressed his negative causation opinion in April 2023, and the

Dispute Certification Notice reflecting Employer’s compensability defense was

issued in July 2023, well before the filing of the motion for summary judgment.

Employee was aware of this defense and took steps to seck expert medical proof to

counter that defense but was unable to do so prior to the summary judgment hearing

in July 2024.

Finally, we note that several cases decided after Goins expressly limited this

holding to the specific facts of that case. For example, in Stapleton v. Mahle, Inc.,

No. 03-S-01-9111-CH-108, 1992 Tenn, LEXIS 453 (Tenn. June 22, 1992), the

Supreme Court noted that its previous holding in Goins was “later limited to its

‘egregious’ facts peculiar to that case.” /d. at *4-5 (citing Dobbs y. Liberty Mut. Ins.

Co., 811 S.W.2d 75, 78 (Tenn. 1991)). The Court in Stapleton also noted that “there

is no language in [section] 50-6-205(d)(1) that can reasonably be read to preclude an

employer who has made temporary disability payment in good faith from raising a

defense to liability for permanent disability.” /d. at *5-6. Moreover, Employee has

presented no statutory or case law after the passage of the Reform Act that supports

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her position. Given the post-reform changes in the language of Tennessee Code

Annotated section 50-6-205(c)-(d), the changes in Tenn, Comp. R. and Regs. 0800-

02-14-.04(8), the discontinuation of the “Notice of Controversy” form, the case law

that expressly limits the holding in Goins, and the post-reform use of the Dispute

Certification Notice to certify disputed issues, we conclude Goins does not dictate

the outcome of this case.

Here, Employer presented expert medical proof from Dr. Czarnecki, a

pulmonologist, indicating that the alleged workplace exposures could not be

identified with any degree of medical certainty as the primary cause of her

pulmonary condition. Moreover, in her responses to Employer’s statement of

undisputed material facts, Employee included the following response to Employer’s

seventh statement:

1, Dr. Czarnecki has examined Employee and opined that

Employee’s injury did not arise out of the course and scope of

her employment with Employer.

Response: [Employee] agrees this fact is undisputed for purposes of

ruling on this summary judgment motion only.

Thus, Employee admitted that Dr. Czarnecki examined her and opined that her

injury did not arise primarily out of and in the course and scope of her employment.

Although Employee submitted a Form C-30A from Dr. Jump, that document was

deemed inadmissible at the summary judgment stage. Further, as the court correctly

noted, Employee’s sworn statement that she contracted COVID-19 while working

does not, standing alone, raise a disputed issue of material fact in light of the

pulmonologist’s causation opinion. See Scott v. Integrity Staffing Sols., No. 2015-

01-0055, 2015 TN Wrk. Comp App. Bd. LEXIS 24, at *11 (Tenn. Workers’ Comp.

App. Bd. Aug. 18, 2015) (“[E]ven under pre-reform law, lay testimony alone was

insufficient in most cases to establish adequate evidence of medical causation.”).

Accordingly, we discern no error by the trial court.

Conclusion

For the foregoing reasons, we affirm the court’s order granting summary

judgment and certify it as final. Costs on appeal are taxed to Employee.

ip) -

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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