The opinion
FILED
Mar 20, 2026
01:52 PM(CT)
TENNESSEE COURT OF
WORKERS' COMPENSATION
CLAIMS
TENNESSEE BUREAU OF WORKERS’ COMPENSATION
IN THE COURT OF WORKERS’ COMPENSATION CLAIMS
AT MURFREESBORO
PAUL SADDLER, Docket No. 2024-50-4774
Employee,
v.
UNITED MECHANICAL AND
ELECTRIC, INC., State File No. 38361-2024
Employer,
and
ACCIDENT FUND INS. CO. OF
AMERICA, Judge Robert Durham
Carrier.
EXPEDITED HEARING ORDER DENYING BENEFITS
On March 4, 2026, the Court held an expedited hearing to determine whether
Mr. Saddler is likely to prove that he suffered an injury arising primarily out of his
employment with United Mechanical. For the reasons below, the Court finds Mr.
Saddler did not meet his burden of proof as to causation and denies his claim for
benefits at this time.
History of Claim
This case is unusual because Mr. Saddler had no memory of how he injured
himself or anything else that happened on May 29, 2024. He only knew that he
worked for United Mechanical as a heating, ventilation, and air-conditioning
installer working at a construction site in Clarksville. He did not present any
witnesses to the incident or what led to emergency medical services being called to
the site.
While emergency personnel were treating Mr. Saddler, he experienced
symptoms that raised concerns of a seizure. He was intubated, sedated, and taken
by helicopter to the hospital, where he was diagnosed with a subdural hematoma and
multiple skull fractures. The emergency record stated that Mr. Saddler had
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“evidence of a significant [closed-head injury] after a fall from 8 feet at 10:30. The
patient reportedly had a non-syncopal fall onto an unknown type of surface at
10:30.” The record continues that Mr. Saddler’s history was “limited to Life Flight
as the patient is intubated and sedated.”
The hospital also conducted a drug screen that was “presumptively positive”
for cannabinoids, although no levels of the drug or evidence of a confirmatory test
were provided. Mr. Saddler testified that he had used vapes with cannabinoids in
the past, but the last time he recalled doing so was at least a week before his injury.
He said that he had never gone to work intoxicated. He also testified that he had
suffered a traumatic brain injury in the past that caused headaches, but he had never
had a seizure.
United Mechanical’s owner testified that on the day of the injury, the company
had been certified as a Tennessee Drug-Free Workplace. He provided a Drug Free
Workplace Application form dated July 26, 2023.
The only description of the incident was contained in Dr. Jeffrey Hazlewood’s
independent medical evaluation report. He said Mr. Saddler’s wife advised that a
coworker told her she was in another room when she heard a “commotion.” She ran
into the other room and found Mr. Saddler unconscious and “apparently he had fallen
off a ladder.” Dr. Hazlewood concluded his report by stating that Mr. Saddler was
not at maximum medical improvement and required additional treatment.
Findings of Fact and Conclusions of Law
Mr. Saddler must prove a likelihood of prevailing at a hearing on the merits.
Tenn. Code Ann. § 50-6-239(c)(6) (2025).
To prove causation, Mr. Saddler must establish that he suffered an injury
caused by a specific incident . . . arising primarily out of and in the course and scope
of employment. This means he must prove that his employment contributed more
than 50% in causing the disablement or need for treatment, “considering all causes.”
Id. § 50-6-102(12)(A)-(B).
Mr. Saddler has shown that he suffered a serious head injury at work.
However, he must still prove that his injury arose primarily out of his employment
and contributed more than 50% in causing his disablement or need for treatment.
An “idiopathic injury” is “one that has an unexplained origin or cause and
generally does not arise out of the employment unless some condition of the
employment presents a peculiar or additional hazard.” Miller v. Logan’s Roadhouse,
Inc., 2018 TN Wrk. Comp. App. Bd. LEXIS 59, at *9 (Nov. 15, 2018). The “focus
2
is on the causal link between the employment and the accident or injury, rather than
a causal link between the employment and the idiopathic episode.” Id.
In Miller, the employee asserted that he fell because fumes and heat caused
him to pass out. He did not have medical proof supporting that assertion but was
able to prove that he was injured because he struck some shelves. Thus, his injury
was “causally related to some incident to the employment,” i.e., the additional hazard
created by the shelves. The Board held the proof was enough at the interlocutory
stage to award benefits. Id. at *10.
Here, Mr. Saddler has offered no evidence as to why he fell. Further, he has
not established any hazard causally related to his injury that was peculiar to his
employment. The only accounts of the incident were speculation and inadmissible
hearsay. But even if they were admissible, they would still not be enough to meet
Mr. Sadler’s burden. Without any admissible evidence linking his employment to
either his fall or his injury, other than the fact that the injury occurred at the
construction site, the Court cannot find at this time that Mr. Saddler is likely to prove
causation at trial.1
IT IS ORDERED:
1. Mr. Saddler’s request for benefits is denied.
2. This case is set for a Scheduling Hearing on May 13, 2026, at 9:00 a.m.
Central Time. The parties must call 615-253-0010. Failure to appear
might result in a determination of the issues without the party’s
participation.
ENTERED March 20, 2026.
____________________________________
JUDGE ROBERT DURHAM
Court of Workers’ Compensation Claims
Exhibits:
1. Dr. Hazlewood’s IME report
2. Wage Statement
1
Because the claim is denied on causation grounds, the Court need not address United
Mechanical’s intoxication defense at this time.
3
3. Notice of Denial
4. Vanderbilt Records
5. Drug Free Workplace Acceptance Notice
4
CERTIFICATE OF SERVICE
I certify that a copy of this Order was sent on March 20, 2026.
Name Email Service sent to:
Lauren Ray X lray@forthepeople.com
Gordon Aulgur Gordon.aulgur@afgroup.com
X
Christine.Spear@afgroup.com
___________________________________
PENNY SHRUM, COURT CLERK
wc.courtclerk@tn.gov
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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 *
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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]
LB-1099 rev. 01/20 Page 2 of 2 RDA 11082