Tennessee: Store Manager’s PTSD Found Compensable After Encounter With Purse Snatchers

A store manager who sustained injuries in her employer’s parking lot after she pursued two persons, posing as customers, who stole her purse from the store, could recover workers’ compensation benefits for psychological injuries in the nature of PTSD, held the Special Workers’ Compensation Appeals Panel of the Supreme Court of Tennessee. Citing Larson’s Workers’ Compensation Law, the panel held that the manager’s injuries arose out of and in the course of her employment since the assault had an “inherent connection” to the employment. The panel indicated the trial court had erroneously based its award of benefits on the so-called “street risk rule.” Under that rule, if the employment involves indiscriminate exposure to the general public, injuries sustained in such encounters are deemed to have been caused by the employment. The panel held that in the instant case, the parking lot was part of the employer’s premises; the trial court need not have resorted to the street risk rule to find a causal connection between the injuries and the workplace.

Thomas A. Robinson, J.D., the Feature National Columnist for the LexisNexis Workers’ Compensation eNewsletter, is the co-author of Larson’s Workers’ Compensation Law (LexisNexis).

LexisNexis Online Subscribers: Citations below link to Lexis Advance. Bracketed citations link to lexis.com.

See Mattress Firm, Inc. v. Mudryk, 2015 Tenn. LEXIS 689 (Aug. 24, 2015) [2015 Tenn. LEXIS 689 (Aug. 24, 2015)]

See generally Larson’s Workers’ Compensation Law, § 13.04 [13.04]

For a more detailed discussion of the case, see http://www.workcompwriter.com/tennessee-mattress-store-manager-prevails-in-ptsd-claim-after-encounter-with-purse-snatching-customers/

Source: Larson’s Workers’ Compensation Law, the nation’s leading authority on workers’ compensation law.