An employee of Gerdau Ameristeel, Steven Ratliff, witnessed the deaths of two co-workers in February and April 2008, leading to his diagnosis of post-traumatic stress disorder (PTSD) on June 23, 2008. He filed a request for a benefit review conference exactly one year later. The employer argued that the statute of limitations on Ratliff's claim began with the second incident and had expired before he filed his request. Ratliff contended that the limitation period started with his diagnosis. The trial court initially ruled in favor of the employer, granting a summary judgment. However, upon appeal, the Supreme Court of Tennessee reversed the trial court's judgment and remanded the case for further proceedings, confirming the alternative findings of the trial court regarding the statute of limitations. The case involved testimony from Dr. Keith Kirby, who attributed Ratliff's PTSD to the traumatic events he experienced at work.
Dr. Kirby treated Mr. Ratliff for PTSD, prescribing various medications and recommending he seek new employment after unsuccessful attempts to return him to his previous job. Dr. Kirby assessed Mr. Ratliff with a 5% permanent impairment but did not impose any permanent activity restrictions. Following his resignation from Ameristeel, Mr. Ratliff briefly worked at Goodyear Tire before leaving due to a back injury and was unemployed during the trial.
The trial court ruled in favor of Ameristeel's motion for summary judgment, determining that the statute of limitations for Mr. Ratliff's claim began on April 4, 2008, the date of Mr. Blackmon's death, thus barring the claim under Tennessee Code Annotated section 50-6-203. The court also provided alternative findings, stating that if the statute of limitations starts upon discovery of the injury, Mr. Ratliff could not have known about his PTSD until June 23, 2008, which would allow for his claim to proceed. Additionally, the court found that Mr. Ratliff had a permanent partial disability of 20% to the body as a whole.
Mr. Ratliff appealed, with the case referred to a Special Workers’ Compensation Appeals Panel, which subsequently transferred the appeal to the full Court. The main legal issue involves interpreting the statute of limitations for workers’ compensation claims as defined in Tennessee Code Annotated section 50-6-203. Historically, conflicting interpretations existed regarding the commencement of the statute of limitations, which the court previously addressed, opting to use the phrasing from section 50-6-224, indicating that the limitation period begins with the occurrence of the injury rather than the accident.
Sections 203 (b)(1) and 224 (a)(1) have been interpreted in various cases to distinguish between the date an "accident resulting in injury" occurs and the "occurrence of [an] injury." Following amendments by the General Assembly in 2004, section 224 applies only to injuries occurring on or before December 31, 2004, making section 203 the sole statute governing claims for injuries arising on or after January 1, 2005. The General Assembly is presumed aware of the differing accrual times established in prior case law, indicating intent for the statute of limitations to commence at the accident date for post-2004 injuries under section 203 (b)(1).
The issue of tolling the statute of limitations until the discovery of an employee's injury has been addressed, with the court affirming that a statute of limitations does not expire before the discovery of a claim. The discovery rule, initially adopted for medical malpractice, has been extended to other negligence claims. Despite arguments that the limitation under section 224 precludes discovery rule applicability in workers' compensation cases, the court disagrees, affirming that the statutes of limitations under both sections 203 and 224 are tolled until the employee is aware of a compensable injury. The court has consistently held that a workers' compensation claim does not accrue until the injury becomes apparent through reasonable diligence, thus suspending the statute of limitations until the injury is discovered.
The statute of limitations under section 224(a)(1) is tolled until an employee discovers that their injury is compensable under workers' compensation statutes. This principle has been upheld in several Tennessee Supreme Court cases, which state that the limitations period begins upon the diagnosis of the injury, or when it is reasonably discoverable. The 2004 amendment to the statutes did not explicitly address the application of the discovery rule, and it is presumed that the General Assembly was aware of prior judicial interpretations when enacting the amendment.
In the case at hand, Mr. Ratliff filed a request for a benefit review conference more than one year after Mr. Blackmon's death but had symptoms of PTSD before June 23, 2008. Deposition testimony indicated that Mr. Ratliff was clinically diagnosed with PTSD on June 23, 2008. The legislative history does not suggest an intention to eliminate the discovery rule for workers’ compensation cases.
It is established that the statute of limitations starts when a claimant could have reasonably discovered their compensable injury. Determining whether a plaintiff exercised reasonable diligence in discovering their cause of action is a question of fact. Therefore, considering the evidence favorably for the non-moving party, summary judgment for Ameristeel is deemed inappropriate regarding whether the statute of limitations bars Mr. Ratliff’s claim.
The trial court's grant of summary judgment regarding the statute of limitations is reversed. Workers' compensation cases are prioritized in the judicial process, necessitating trial courts to rule on the merits even in procedural resolutions. In this instance, the trial court appropriately examined the case on its merits and provided alternative findings after granting summary judgment in favor of the employer.
The court found that Mr. Ratliff could not have reasonably linked his PTSD symptoms to his work activities until his diagnosis on June 23, 2008. Despite experiencing symptoms like anxiety and crying spells following a work-related accident, Mr. Ratliff was unaware of his condition until diagnosed, having been previously unfamiliar with the term "post-traumatic stress disorder." Dr. Kirby confirmed Mr. Ratliff's clinical diagnosis of PTSD on the date in question.
The court noted that credibility and weight of testimony are primarily assessed by the trial court, which had the opportunity to hear from Mr. Ratliff and review Dr. Kirby's deposition. The trial court concluded that Mr. Ratliff could not have identified his PTSD as work-related prior to his diagnosis, establishing that the statute of limitations began upon diagnosis. Consequently, the limitations period did not preclude Mr. Ratliff’s claim, and he is entitled to a permanent partial disability award of 20% to the body as a whole, a finding not contested by Ameristeel.
The judgment is reversed, and the case is remanded for the entry of judgment awarding Mr. Ratliff the specified disability benefits, with costs imposed on Gerdau Ameristeel, Inc.
