A Tennessee judge has tossed a HUB Group injury claim, ruling the worker had no medical proof his strokes came from the job.
Bobby Williams said he was hurt on March 28, 2022, after walking out of a truck-stop bathroom and feeling so dizzy he had to lower himself to the ground. He sought workers' compensation benefits from HUB Group, Inc. for injuries to his head and brain.
The case turned on causation – whether the job actually caused the injury.
Williams' own neurologist, Dr. Lucas Elijovich, diagnosed him with two strokes. One happened in 2015. The doctor could not pinpoint when the other occurred. He also testified the strokes were not primarily caused by anything Williams did or experienced at work.
Williams offered no competing medical opinion. He argued that because the incident happened at work and because Dr. Elijovich had diagnosed strokes, the injury must be work-related.
Tennessee law says that is not enough. Under Tenn. Code Ann. § 50-6-102(12), an injured worker needs expert medical proof that the injury arose primarily out of and in the course and scope of employment, given within a reasonable degree of medical certainty. A worker's own opinion on cause does not clear the bar.
Judge Shaterra R. Marion of the Court of Workers' Compensation Claims at Memphis granted HUB Group summary judgment – a ruling that ends a case without trial when the key facts are not really in dispute. Williams had filed a response to the motion but did not answer HUB's statement of undisputed facts, so those facts went unchallenged.
The judge pointed to Hutchins v. Cardinal Glass Industries, a recent ruling that upheld summary judgment where an employee failed to produce medical evidence of causation. The same gap sank Williams' case.
The claim was dismissed with prejudice, meaning Williams cannot refile. The court taxed the $150 filing fee to HUB. The order, entered May 19, becomes final 30 days after entry unless appealed.
For claims professionals, the takeaway is clean. In Tennessee, an injury happening at work is not the same as an injury caused by work. Without an expert medical opinion linking the two, the claim does not survive a summary judgment motion.
