The opinion
FILED
Mar 09, 2026
01:16 AM(CT)
TENNESSEE COURT OF
WORKERS' COMPENSATION
CLAIMS
TENNESSEE BUREAU OF WORKERS’ COMPENSATION
IN THE COURT OF WORKERS’ COMPENSATION CLAIMS
AT NASHVILLE
ADRIANNE EASON, Docket No. 2025-60-2340
Employee,
v.
FEDERAL EXPRESS
CORPORATION, State File No. 59712-2023
Employer,
and
INDEMNITY INSURANCE
COMPANY OF NORTH Judge Joshua D. Baker
AMERICA,
Carrier.
EXPEDITED ORDER DENYING BENEFITS
At an expedited hearing on March 4, 2026, Ms. Eason requested medical
treatment for a left-knee mass, which developed after an August 2, 2023 work injury.
Federal Express asserted the statute of limitations bars Ms. Eason’s claim because
she did not file a petition within one year after the last payment on her claim.
Because Ms. Eason did not file her petition timely or raise any applicable
exceptions to the limitations defense, the Court finds she is unlikely to prevail at a
final hearing.
Claim History
While working for Federal Express on August 2, 2023, Ms. Eason strained
her wrists, knees, and right ankle from jumping onto a loading dock to avoid being
hit by a cargo tug. She received treatment until August 21, 2023, when her authorized
doctor discharged her at maximum recovery.
1
More than a year later, in October 2024, she noticed a lump below her left
kneecap. Over the next several months, she tried to doctor it herself. Ultimately, she
emailed Federal Express on March 18, 2025, to ask for medical treatment.
However, the claim’s adjuster refused to authorize treatment because Ms.
Eason had not filed a petition within one year from the last payment on her claim.
At the hearing, Federal Express entered the adjuster’s affidavit into evidence with
an attached payment ledger showing the claim’s last payment issued March 8, 2024.
After Federal Express refused her treatment, Ms. Eason filed her petition on
April 10, 2025.
Factual Findings and Legal Conclusions
The Workers’ Compensation Law governs when a petition must be filed
where an employer paid benefits voluntarily, as here. Under the statute, “the right to
compensation is forever barred, unless a petition for benefit determination is filed .
. . within one (1) year from the latter of the date of the last authorized treatment or
the time the employer ceased to make payments of compensation to or on behalf of
the employee.” Tenn. Code Ann. § 50-6-203(b)(2) (2025).
Here, Ms. Eason’s last date of authorized treatment was August 21, 2023.
Federal Express last paid benefits March 8, 2024, making that “the latter” date. Ms.
Eason filed her petition more than a year later, on April 10, 2025.
Contrary to Ms. Eason’s argument at trial, the “issuing date of the last
payment of compensation by the employer, not the date of its receipt shall constitute
the time the employer ceased to make payments of compensation.” Carpenter v. Am.
Water Heater Co., 2024 TN Wrk. Comp. App. Bd. LEXIS 26, at *6-7 (July 12, 2024)
(citing Tenn. Code Ann. § 50-6-203(c)). In Carpenter, issuance of the last voluntary
payment of benefits to a medical provider triggered the running of the one-year
statute of limitations.
Given that, the Court’s decision is constrained by the date the last voluntary
payment issued rather than the date the check cleared. Further, the date Ms. Eason
requested medical treatment is immaterial, where the law requires a petition. Also,
Ms. Eason did not present any applicable exceptions to suggest her claim is not
barred by the statute of limitations.
The Court finds Ms. Eason is unlikely to prevail at a final hearing given the
date Federal Express last paid benefits and the date she filed her petition.
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It is ORDERED as follows:
1. Ms. Eason’s request for benefits is denied at this time.
2. The Court sets a status hearing for Tuesday, April 28, 2026, at 9:30 a.m.
Central Time. The parties must call (615) 741-2113 or (855) 874-0474 to
participate. Failure to call might result in a determination of the issues without
your participation.
ENTERED March 9, 2026.
________________________________________
JUDGE JOSHUA D. BAKER
Court of Workers’ Compensation Claims
3
CERTIFICATE OF SERVICE
I certify that a copy of this Order was sent as shown on March 9, 2026.
Certified Regular
Name Email Sent to
Mail mail
Adrianne Eason, easonadrianne@gmail.com
X
Employee
Jamie Glass, jamie.glass@qpwblaw.com
Jonathan West, jonathan.west@qpwblaw.com
X
Employer’s judy.hamer@qpwblaw.com
attorneys
_______________________________________
Penny Shrum
Clerk, Court of Workers’ Compensation Claims
WC.CourtClerk@tn.gov
4
Right to Appeal:
If you disagree with the Court’s Order, you may appeal to the Workers’ Compensation
Appeals Board. To do so, you must:
1. Complete the enclosed form entitled “Notice of Appeal” and file it with the Clerk of the
Court of Workers’ Compensation Claims before the expiration of the deadline.
¾ If the order being appealed is “expedited” (also called “interlocutory”), or if the
order does not dispose of the case in its entirety, the notice of appeal must be filed
within seven (7) business days of the date the order was filed.
¾ If the order being appealed is a “Compensation Order,” or if it resolves all issues
in the case, the notice of appeal must be filed within thirty (30) calendar days of
the date the Compensation Order was filed.
When filing the Notice of Appeal, you must serve a copy on the opposing party (or attorney,
if represented).
2. You must pay, via check, money order, or credit card, a $75.00 filing fee within ten calendar
days after filing the Notice of Appeal. Payments can be made in-person at any Bureau office
or by U.S. mail, hand-delivery, or other delivery service. In the alternative, you may file an
Affidavit of Indigency (form available on the Bureau’s website or any Bureau office)
seeking a waiver of the filing fee. You must file the fully-completed Affidavit of Indigency
within ten calendar days of filing the Notice of Appeal. Failure to timely pay the filing
fee or file the Affidavit of Indigency will result in dismissal of your appeal.
3. You are responsible for ensuring a complete record is presented on appeal. If no court
reporter was present at the hearing, you may request from the Court Clerk the audio
recording of the hearing for a $25.00 fee. If you choose to submit a transcript as part of your
appeal, which the Appeals Board has emphasized is important for a meaningful review of
the case, a licensed court reporter must prepare the transcript, and you must file it with the
Court Clerk. The Court Clerk will prepare the record for submission to the Appeals Board,
and you will receive notice once it has been submitted. For deadlines related to the filing of
transcripts, statements of the evidence, and briefs on appeal, see the applicable rules on the
Bureau’s website at https://www.tn.gov/wcappealsboard. (Click the “Read Rules” button.)
4. After the Workers’ Compensation Judge approves the record and the Court Clerk transmits
it to the Appeals Board, a docketing notice will be sent to the parties.
If neither party timely files an appeal with the Appeals Board, the Court Order
becomes enforceable. See Tenn. Code Ann. § 50-6-239(d)(3) (expedited/interlocutory
orders) and Tenn. Code Ann. § 50-6-239(c)(7) (compensation orders).
For self-represented litigants: Help from an Ombudsman is available at 800-332-2667.
NOTICE OF APPEAL
Tennessee Bureau of Workers’ Compensation
www.tn.gov/workforce/injuries-at-work/
wc.courtclerk@tn.gov | 1-800-332-2667
Docket No.: ________________________
State File No.: ______________________
Date of Injury: _____________________
___________________________________________________________________________
Employee
v.
___________________________________________________________________________
Employer
Notice is given that ____________________________________________________________________
[List name(s) of all appealing party(ies). Use separate sheet if necessary.]
appeals the following order(s) of the Tennessee Court of Workers’ Compensation Claims to the
Workers’ Compensation Appeals Board;ĐŚĞĐŬŽŶĞŽƌŵŽƌĞĂƉƉůŝĐĂďůĞďŽdžĞƐĂŶĚŝŶĐůƵĚĞƚŚĞĚĂƚĞĨŝůĞͲ
ƐƚĂŵƉĞĚŽŶƚŚĞĨŝƌƐƚƉĂŐĞŽĨƚŚĞŽƌĚĞƌ;ƐͿďĞŝŶŐĂƉƉĞĂůĞĚͿ͗
ප Expedited Hearing Order filed on _______________ ප Motion Order filed on ___________________
ප Compensation Order filed on__________________ ප Other Order filed on_____________________
issued by Judge _________________________________________________________________________.
Statement of the Issues on Appeal
Provide a short and plain statement of the issues on appeal or basis for relief on appeal:
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
________________________________________________________________________________________
Parties
Appellant(s) (Requesting Party): _________________________________________ ܆Employer ܆Employee
Address: ________________________________________________________ Phone: ___________________
Email: __________________________________________________________
Attorney’s Name: ______________________________________________ BPR#: _______________________
Attorney’s Email: ______________________________________________ Phone: _______________________
Attorney’s Address: _________________________________________________________________________
* Attach an additional sheet for each additional Appellant *
LB-1099 rev. 01/20 Page 1 of 2 RDA 11082
Employee Name: _______________________________________ Docket No.: _____________________ Date of Inj.: _______________
Appellee(s) (Opposing Party): ___________________________________________ ܆Employer ܆Employee
Appellee’s Address: ______________________________________________ Phone: ____________________
Email: _________________________________________________________
Attorney’s Name: _____________________________________________ BPR#: ________________________
Attorney’s Email: _____________________________________________ Phone: _______________________
Attorney’s Address: _________________________________________________________________________
* Attach an additional sheet for each additional Appellee *
CERTIFICATE OF SERVICE
I, _____________________________________________________________, certify that I have forwarded a
true and exact copy of this Notice of Appeal by First Class mail, postage prepaid, or in any manner as described
in Tennessee Compilation Rules & Regulations, Chapter 0800-02-21, to all parties and/or their attorneys in this
case on this the __________ day of ___________________________________, 20 ____.
______________________________________________
[Signature of appellant or attorney for appellant]
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