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Primm, Chad v. Central Sales & Service, Inc.

2026-06-24No. 2025-60-3209

Summary

Holding. The court granted benefits and awarded permanent partial disability at 7% (rejecting the employee's claimed 12% rating and the employer's 7% rating based on competing medical evidence), past temporary partial disability benefits covering the period from February 22 through September 3, 2025, future medical benefits with the treating physician, and discretionary costs. The court denied permanent total disability and dismissed the Subsequent Injury and Vocational Recovery Fund with prejudice.

Chad Primm suffered a herniated disc at the L5-S1 level while lifting a steel slab at his job as a production supervisor. He sought permanent total disability benefits, alternatively arguing he deserved a 12% impairment rating. The employer and its insurer contested the rating and the termination of his employment, while the Subsequent Injury Fund denied liability.

The court found that Primm did not meet his burden of proving permanent total disability. The court credited his testimony regarding severe, disabling pain and limited physical capacity but noted his education, work experience, entrepreneurial efforts, and the fact that both treating physicians believed he could work in some capacity. The court also found that his termination was motivated by his inability to meet job demands due to the work injury, not by misconduct, and awarded temporary partial disability benefits from early February through September 2025.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether employee proved permanent total disability
  • Proper impairment rating under AMA Guides (Class 1 versus Class 2 for disc herniation with radiculopathy)
  • Whether termination for poor job performance constituted misconduct or was caused by work-related injury
  • Validity of work restrictions imposed by physician assistants rather than treating physicians

Procedural posture

The workers' compensation judge heard the compensation case on June 3, 2026, and issued a Compensation Order on June 24, 2026.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

FILED

Jun 24, 2026

10:04 AM(CT)

TENNESSEE COURT OF

WORKERS' COMPENSATION

CLAIMS

TENNESSEE BUREAU OF WORKERS’ COMPENSATION

IN THE COURT OF WORKERS’ COMPENSATION CLAIMS

AT NASHVILLE

Chad Primm, Docket No. 2025-60-3209

Employee,

v.

Central Sales & Service, Inc.,

Employer, State File No. 3061-2025

Auto-Owners Ins. Co.,

Carrier,

And

Troy Haley, Administrator, Judge Kenneth M. Switzer

Subsequent Injury and Vocational

Recovery Fund.

COMPENSATION ORDER GRANTING BENEFITS

In this accepted claim, the principal issue is the extent of Chad Primm’s

permanent impairment from a low-back injury he suffered while lifting a heavy

object for Central Sales & Service on January 6, 2025.

The parties clash on the correct impairment rating. Mr. Primm contended he

is entitled to permanent total disability or at least 12% with a future claim for

extraordinary benefits. Central Sales argued that Mr. Primm is only entitled to an

original award of 7% permanent partial disability. The Subsequent Injury and

Vocational Recovery Fund denied any liability.

Mr. Primm and Central Sales also disputed whether Mr. Primm is entitled to

past temporary disability and the circumstances of him leaving his employment.

After a compensation hearing on June 3, 2026, the Court finds that Mr. Primm

is not permanently and totally disabled, retained a 7% permanent partial impairment,

and is entitled to past temporary disability benefits from Central Sales. The Fund

has no liability.

1

Claim History

Mr. Primm’s testimony

Mr. Primm, age 51, recalled that on the date of the work incident, he picked

up a steel slab. As he turned, “It felt like somebody stabbed me in my lower back[.]” A year and a half later, he said his condition is worsening not improving.

Mr. Primm has not worked since the injury due to severe daily back pain and

numbness in both legs. The pain interferes with his sleep and prevents him from

doing chores around the house or pursuing his former hobbies. Prescribed

medications, physical therapy, and injections have brought little or no relief.

In addition to pain, Mr. Primm described other physical limitations that

prevent him from working. Sitting for longer than half an hour at a time is difficult. Bending over to retrieve an object is also challenging. He cannot stand for long

periods of time, lift, or twist. He can drive but must take frequent breaks.

As for his education and work history, Mr. Primm has a high school diploma

and attended college for “half a semester.” His first jobs were mostly as a laborer

until he started working in industrial maintenance, which he has done for well over

a decade and was his field at Central Sales. At the time of his injury, he was a

production supervisor in the cleat department. Mr. Primm directed the work of three

other “operators” but also performed the same work alongside them.

Their workdays consisted of using water jets to cut rubber cleats and then

boxing and loading them on pallets. They also cut and lifted extrusion dies, which

are half-inch steel plates weighing anywhere from 80 to 100 pounds. The job was

fast-paced and involved constant lifting, and he was on his feet for most of his

workdays. His position also occasionally required reading and revising blueprints,

but Mr. Primm said he could not create them himself. He has a welding certificate.

Mr. Primm said he had no previous back injuries or workers’ compensation

claims. This statement was contradicted somewhat by medical records from before

the injury. In 2020, he had a cyst at the bottom of his spine that was lanced, and on cross-examination by Central Sales, he agreed that in 2017 he was treated for a boil

on his back. He further acknowledged that a medical record from that same year

stated that he was seen for “workers’ comp and knee pain.” But on questioning by

the Fund, Mr. Primm could not recall filing a claim, receiving significant treatment

2

or an impairment rating, or settling. He maintained he had no previous disabilities

or restrictions before January 6, 2025.

Central Sales vigorously cross-examined Mr. Primm, questioning his

credibility on numerous other matters. For example, he acknowledged using a

product known as kratom frequently while working for “energy.”

In addition, Mr. Primm said on cross that he started a business called Primm

Powder Coating in October 2024. This short-term business consisted of powder

coating auto parts to make the parts more durable. Mr. Primm learned the process

by watching online videos. He stopped after the injury because he could no longer

do the work.

Mr. Primm acknowledged a few incomplete or inaccurate responses to

discovery relating to his business. When confronted with bank statements showing

minimal deposits related to Primm Powder Coating, he clarified that all work was

done before the work injury. He similarly did not produce the requested copies of

photos or videos of work performed for the business, and he answered “none” to a

request asking for copies of correspondence with customers. Mr. Primm said any

photos, videos, or emails were deleted. He further said that a post-injury social

media ad for the business was intended for his son to do the work. But, his son

eventually took another job, and the post should have been taken down.

Treatment

Mr. Primm went to the emergency room two days after the accident.

Afterward, Central Sales gave a panel, and he chose an orthopedic specialty clinic.

He saw a physician assistant two weeks later. She ordered an MRI and physical

therapy and placed work restrictions. A month later, the physician assistant ordered

additional physical therapy and an injection, and she kept restrictions in place. Then, in March, another physician assistant referred Mr. Primm to a spine specialist and

took him off work for eight days.

Mr. Primm saw authorized physician Dr. Scott Standard in late July, who

recorded the failure of conservative treatment and diagnosed a herniated disc at L5-S1. He recommended another injection but wrote that if it failed to bring relief,

surgery would be necessary.

3

At the next visit on September 3, Dr. Standard noted improvement in Mr.

Primm’s pain level and he was “not needing surgical management at this time.” Mr.

Primm said that the doctor examined him for about five minutes. Dr. Standard

assigned maximum medical improvement, a 12% impairment, and a permanent

restriction of no lifting more than 35 pounds. He released Mr. Primm from

treatment.

Approximately two months later, Mr. Primm attended an employer’s

examination with Dr. John Brophy. In the review of symptoms, Mr. Primm

confirmed back pain radiating down both legs but denied “muscle weakness” and

“neurologic weakness.” Dr. Brophy assigned a 7% impairment but placed no

restrictions. Notes from the exam stated that they discussed “the possibility of

improvement in the disc herniation over time and the option of returning to an

alternative career requiring less heavy lifting.”

Expert proof

Dr. Standard testified that, at the first office visit, Mr. Primm was “obviously

in a significant amount of pain.” He performed a physical exam lasting

approximately five minutes. He reviewed the MRI film and diagnosed degenerative

disc disease in the lumbar spine and a disc herniation on the left at L5-S1. Mr.

Primm had radiculopathy at that visit, as well as pain when sitting, standing, “or

lifting anything significant.”

After another injection and more physical therapy, Mr. Primm reported a pain

level of 2/10 at the second and final visit. Dr. Standard performed a “superficial

exam” on that date but did not record that in the records. He placed a permanent 35-pound lifting restriction because it is “standard” and within the “medium demand

category.” As for limits on sitting or standing, Dr. Standard placed no restriction

but said Mr. Primm should “self-manage.” He believed Mr. Primm’s standing

ability should improve over time.

Dr. Standard explained how he arrived at his rating. He used the AMA

Guides, table 17-4 on page 570. He placed Mr. Primm in “Class 2, which is

intervertebral disc herniation at a single level, medically documented findings, with or without surgery, and documented radiculopathy at the clinically appropriate level

at the time of the examination.” He added that Class 1 is inappropriate “[b]ecause

he had radiculopathy and a herniated disc.” On cross, Dr. Standard said that at the

4

second visit, he did not record numbness—just at the initial exam—but he said Mr.

Primm had numbness at maximum medical improvement.

Dr. Standard testified that Mr. Primm was unable to return to the same type

of work he did before the injury. On cross, he clarified that he was not saying that

Mr. Primm “couldn’t go back to work.”

For his part, Dr. Brophy testified he is a member of the Bureau’s Certified

Physician Program and the Workers’ Compensation Medical Advisory Committee.

He, too, reviewed the actual imaging and Dr. Standard’s records.

Dr. Brophy performed a 20-minute examination to include strength-testing in

both extremities, sensory touch, and deep tendon reflexes. Dr. Brophy agreed with

Dr. Standard’s diagnosis that Mr. Primm had an S1 radiculopathy, secondary left

L5-S1 herniated disc.

Dr. Brophy placed a 7% rating using the Guides, table 17.4, Class 1. He chose

Class 1 because “transitioning from class I to class II, it has to be something

objective about the radiculopathy and that means weakness. Nobody ever

documents weakness, so he remains class I, which is 7 percent.”

On cross, Dr. Brophy said that weakness is not the only criterion for a clinical

diagnosis of radiculopathy, but it is necessary for transitioning from Class 1 to Class 2. He reiterated, “[W]eakness is necessary to qualify for class II. Otherwise, it’s

arbitrary.” He added, “You can have a horrible radiculopathy with incapacitating

pain and a huge ruptured disk and not have weakness.”

On redirect, the following exchange occurred while reviewing the applicable

table on page 570:

Q: Can you just expand upon why you did not move it into the class II

seeing this?

A: Well, documented residual radiculopathy to me requires something

objective, meaning weakness, not just having leg pain, so then you go

to 12 percent. That doesn't make sense to me.

Q: So, would you consider leg pain to be a non-verifiable radicular

complaint?

A: Yes.

5

Dr. Brophy placed no work restrictions, stating that Mr. Primm “has no

neurologic deficit and he was in no significant pain at this time.” He explained: “I

think generally speaking . . . there has to be some reason other than subjective pain to justify a permanent restriction, and, potentially make someone unemployable.”

Dr. Brophy additionally disagreed that Mr. Primm cannot return to his pre-injury

occupation, saying that Dr. Standard considered Mr. Primm’s “subjective pain.”

The termination

Mr. Primm described his pre-injury job performance as “excellent.” He

recalled the cleat department breaking production records, and at one point, they

were three or four weeks ahead on their orders. After the injury, Central Sales

offered light-duty as ordered by the physician assistant, but he still had difficulty meeting the job demands and had to sit often due to pain.

Mr. Primm said that Daniel Deaver, Central Sales’ (now) president,

terminated him on February 21, 2025, due to poor job performance and attendance.

He said his absences were due to medical appointments and physical therapy for the

injury. Mr. Primm was upset about his termination, but now he understands the

decision. “I just couldn’t do the job,” he said, noting the time-sensitivity of the work. He denied that at a lunch meeting a few months before the injury, two supervisors

discussed with him their concerns about his job performance. No one ever relayed

concerns about production in the cleat department, and in fact, Mr. Deaver praised

his work.

Mr. Deaver testified that the termination was justified. He explained that Mr.

Primm started in a different department, extrusion. Mr. Deaver said that while Mr.

Primm was in that position, he heard “reports that there were some issues with his

job performance and attendance[.]” While Mr. Primm worked night shifts, Mr.

Deaver “heard reports that he was going out to his car a lot at night—things like that. I don’t have any specifics, any proof of that—those were just the things that I heard.” He said the plant manager in extrusion said he “can’t trust him to be over here,” so

they moved Mr. Primm to the cleat department instead of letting him go.

As for his job performance there, Mr. Deaver said that early on, the company

had “issues” with meeting the production schedule. He had concerns about Mr.

Primm’s organizational skills, noting, “We felt like he wasn’t using his time wisely.” He also said the employees Mr. Primm supervised “seemed a little bit disgruntled.

They complained a lot about working for him, that he wasn’t setting them up for

success a lot.” Mr. Deaver said he saw Mr. Primm on his phone or “just hanging out

6

by the water jets.” He said “a couple times” the company talked to Mr. Primm about

their concerns. Further, “I saw multiple instances where it looked like he was just

watching videos on his phone.”

Mr. Deaver agreed that the company provided light duty after the accident but

said Mr. Primm should have been able to do the accommodated work. Devices or

coworkers could have helped him with lifting. As to Mr. Primm’s job performance,

he “couldn’t see an appreciable difference from before the injury to after the injury.” Mr. Deaver said that the company has sitting-only positions in other divisions, such

as the sewing department.

Mr. Deaver did not “take issue with” excused absences for doctor or therapy

visits, but he said that Mr. Primm had “sort of a bad attendance record as well,

coming in late, asking if he could leave a few minutes early for this or that.” Mr.

Deaver stated that some of these instances were recorded, but he offered no

documentation. Discussions took place about terminating Mr. Primm before the

injury, but Mr. Deaver did not say who participated in them, when, or how often

they occurred. He said two other supervisors went to lunch with Mr. Primm before

the injury to discuss their concerns. Mr. Deaver did not attend that lunch.

On cross-examination, Mr. Deaver agreed that Central Sales produced Mr.

Primm’s personnel records, and they contained “no negative reports.” He could not

recall praising Mr. Primm because the cleat department output was increased; he

said the increase overall was due to work in different departments.

Findings of Fact and Conclusions of Law

Mr. Primm has the burden of proof on all essential elements of his claim and

must show by a preponderance of the evidence that he is entitled to the requested

benefits. Tenn. Code Ann. § 50-6-239(c)(6) (2025); Willis v. All Staff, 2015 TN

Wrk. Comp. App. Bd. LEXIS 42, at *18 (Nov. 9, 2015).

Permanent total disability

To prevail on this claim, Mr. Primm must show that he is “totally

incapacitated from working at an occupation that brings [him] an income,” meaning

he is unable to work at any job in the open labor market. Tenn. Code Ann. § 50-6-207(4)(B); Duignan v. Stowers Mach. Corp., No. E2018-01120-SC-R3-WC, 2019

Tenn. LEXIS 224, at *21 (Tenn. Workers’ Comp. Panel June 19, 2019).

7

The permanent and total disability assessment is based upon numerous

factors, including the employee’s skills and training, education, age, local job

opportunities, and capacity to work at the kinds of employment available in his

disabled condition. Id. at *21-22. Although a rating of anatomical disability by a

medical expert is also one of the relevant factors, “the vocational disability is not restricted to the precise estimate of anatomical disability made by a medical

witness.” Henson v. City of Lawrenceburg, 851 S.W.2d 809, 812 (Tenn. 1993). In

addition, the employee’s own “assessment of his physical condition and resulting

disabilities is competent testimony and cannot be disregarded[.]” Duignan, 2019

Tenn. LEXIS 224 at *22.

Considering the above, Mr. Primm has experience in industrial maintenance,

supervising employees, and reading and changing blueprints occasionally. He also

has a welding certificate. He has shown an entrepreneurial ability, started Primm

Powder Coatings, and provided a service for which he is self-taught. Mr. Primm has

a high school education and “some college.” He was articulate in his testimony. He

is 51 years old. Notably, both doctors believed Mr. Primm is capable of some work.

This all weighs against a finding that he is permanently and totally disabled.

Moreover, Mr. Primm gave no proof on local job opportunities or his capacity to

work at the kinds of employment available.

Mr. Primm credibly testified that he suffers daily, severe, and disabling back

pain and leg numbness. Despite Central Sales’ extensive efforts to attack his

credibility, the Court affords little weight to its cross-examination. To the extent

that Mr. Primm gave incomplete responses to written discovery, the Court frowns

upon that. However, Mr. Primm adequately explained most of the discrepancies

Central Sales identified. In addition, “if minor and insignificant details vary, an

injured worker should not be penalized simply for being a poor historian.” Orman

v. Williams Sonoma, Inc., 803 S.W.2d 672, 677 (Tenn. 1991).

The Court credits Mr. Primm’s description of how the injury affected his

ability to work and daily life. He said that driving, sitting, or standing for long

periods is difficult, and he cannot twist. But Dr. Standard did not place restrictions reflecting these limitations, while Dr. Brophy placed no restrictions at all.

Considering the proof, the Court cannot conclude that Mr. Primm has shown

by a preponderance of the evidence that he is permanently and totally disabled. That

claim is denied.

8

Therefore, the Fund has no liability. See Tenn. Code Ann. § 50-6-208(a)(1)

(Fund’s liability requires findings of permanent total disability and that the employee “previously sustained a permanent physical disability.”).

Original award

Given the above ruling, the Court must determine Mr. Primm’s original award

under section 50-6-207(3)(A). Dr. Standard’s 12% rating is presumed accurate but

may be rebutted by a preponderance of the evidence. Id. § 50-6-204(k)(7). Central

Sales contended that Dr. Brophy’s 7% rating rebuts the presumption.

When presented with competing expert opinions, the Court can consider their

qualifications, the circumstances of their examinations, the information available to them, and the importance attached to the information by other experts. Orman, 803

S.W.2d at 676.

Here, both physicians are well-qualified neurosurgeons. Dr. Brophy has

undergone additional training with the Bureau. This factor favors him slightly. Both

physicians viewed the actual films from the imaging. Dr. Standard’s notes suggest

he read records of previous authorized treatment at the first visit, and Dr. Brophy

reviewed them before the employer’s exam and his deposition. This factor favors

neither physician. Dr. Standard treated Mr. Primm twice, while Dr. Brophy saw him

once for an opinion for litigation. This factor favors Dr. Standard only slightly.

The importance attached to the information they considered is what

differentiates their opinions.

Dr. Standard placed Mr. Primm in Class 2. The Guides on page 570 state in

part that Class 2 requires “documented residual radiculopathy at the clinically

appropriate level present at the time of examination.” Looking at Dr. Standard’s

September 3 notes, as Central Sales stated, no physical exam is documented. Mr.

Primm recalled a brief, five-minute exam, and when pressed on this point at his

deposition, Dr. Standard called it a “superficial exam.” Importantly, Dr. Standard’s

notes do not mention “documented” residual radiculopathy or verified weakness.

Rather, Dr. Standard recalled that Mr. Primm had “numbness” at the first exam.

Overall, the notes from the visit where he assigned the rating are cursory at best.

9

In contrast, Dr. Brophy performed a 20-minute examination and concluded

that Mr. Primm should be considered as Class 1. In part, this requires “nonverifiable radicular complaints at clinically appropriate level(s), present at the time of

examination.” In other words, Mr. Primm did not report any muscular or

neurological weakness. Dr. Brophy testified—repeatedly—that Mr. Primm’s pain

is a nonverifiable radicular complaint.

The Court finds Dr. Brophy gave the more plausible and detailed explanation

for his rating, so Central Sales has rebutted by a preponderance of the evidence the

presumption attached to Dr. Standard’s rating. Mr. Primm retains a 7% medical

impairment, entitling him to an original award of $15,303.02.

Temporary partial disability

Temporary partial disability refers to the time during which the injured

employee can resume some gainful employment but has not reached maximum

recovery. Mace v. Express Servs., Inc., 2015 TN Wrk. Comp. App. Bd. LEXIS 49,

at *8 (Dec. 11, 2015).

Central Sales first argued that a physician assistant rather than a physician

placed Mr. Primm’s restrictions, so the restrictions need not be honored. The Court

disagrees.

Tennessee Compilation Rules and Regulations 0800-02-01.06(7) (2018)

permits physician assistants under the supervision of a licensed physician to provide medical treatment, but only a supervising physician may determine medical

causation, a permanent impairment rating, and the date of maximum medical

improvement. Notably absent from this list is placing work restrictions.

Central Sales cited no authority stating that a physician assistant cannot assign

restrictions. Further, by Mr. Primm’s unrefuted testimony, he saw the physician

assistants by choosing them from a panel that Central Sales offered. Mr. Deaver

testified that when the physician assistant placed the restrictions, Central Sales

honored them. This argument is unavailing.

Next, Central Sales argued that Mr. Primm was terminated for cause. Even

though an employee has a work-related injury for which temporary benefits are

payable, an employer may still enforce workplace rules. Mace, 2015 TN Wrk.

Comp. App. Bd. LEXIS 49 at *8. Further, “[a]n employer will not be penalized for

10

enforcing a policy if the court determines (1) that the actions allegedly precipitating the employee’s dismissal qualified as misconduct under established or ordinary

workplace rules and/or expectations; and (2) that those actions were, as a factual

matter, the true motivation for the dismissal.” Id. at *9.

Mr. Deaver testified that Central Sales terminated Mr. Primm mostly due to

concerns about how Mr. Primm used his time and the cleat department’s resulting

production levels. Meeting production is an ordinary workplace rule or expectation.

But Mr. Deaver’s vague testimony, rife with hearsay, was unpersuasive.

For example, pre-injury, Mr. Deaver said the extrusion manager told him he

could not trust Mr. Primm. Further, while in extrusion, Mr. Deaver “heard reports”

that Mr. Primm left the workplace excessively to go to his vehicle. He

acknowledged, however, that he had no “specifics” or “proof” about this. Both

instances are hearsay, and the Court gives them little weight.

Once Mr. Primm was moved to the cleat department, Mr. Deaver said the

employees he supervised complained. This is also hearsay. Mr. Deaver saw Mr.

Primm on his phone, watching a video and/or “hanging out” by the water jets. But

again, the details are lacking. Further, Mr. Deaver did not attend the lunch where

supervisors supposedly conveyed their concerns to Mr. Primm, so he has no actual

knowledge of what was discussed.

Mr. Deaver said that sitting-only positions were available at Central Sales.

But when concerns apparently arose, Central Sales did not offer Mr. Primm a

different, sitting-only position. They terminated him.

An employer need not offer written documentation to prove a rule’s existence.

Womble v. Uncle Dave’s Auto Repair, Inc., 2018 TN Wrk. Comp. App. Bd. LEXIS

61, at *8 (Dec. 10, 2018). Still, Central Sales offered no evidence to corroborate Mr. Deaver’s testimony. It introduced no paperwork about its workplace rules and

expectations, or its efforts to coach, warn, or discipline Mr. Primm when concerns

about his job performance arose before the injury. Mr. Primm’s personnel file exists; it contains nothing negative.

In contrast, Mr. Primm credibly testified to the quality of his work, pre- and

post-injury. He recalled the lunch but said the conversation focused solely on

meeting the demands of upcoming work. Mr. Primm emphatically denied that his

supervisors questioned his production levels. He said the department set production

records and was at times weeks ahead of schedule. Arguably, Mr. Primm offered

11

little detail and no documentation to support his testimony, either. But Mr. Primm

also candidly admitted that he just could not do the job after the injury. His

testimony was sincere.

Under these circumstances, the Court cannot find that Mr. Primm engaged in

“misconduct under established or ordinary workplace rules and/or expectations.”

Nor can the Court find that his actions were, as a factual matter, the true motivation for his dismissal.

Rather, Mr. Primm acknowledged that post-injury, he did not meet the

physical demands of his job. The Court finds that he could not do so due to the work

injury. His inability to meet production from the work injury was Central Sales’ true motivation for letting him go.

Therefore, Mr. Primm has shown by a preponderance of the evidence that he

is entitled to temporary partial disability benefits from February 22 through

September 3 in the amount of $13,463.87.

Costs

Mr. Primm requested the following discretionary costs: Bertram Reporting,

Dr. Standard’s deposition, $662.80; Lexitas Court Reporting, $525.50; Dr. Brophy’s

Deposition, $750.00; and Veritext Corporate Services, LLC, Mr. Primm’s

deposition, $469.50. Central Sales countered that if the Court awards permanent

partial disability benefits based on Dr. Brophy’s 7% impairment rating, the

discretionary costs should be limited to the $469.50 incurred for the transcript from Mr. Primm’s deposition.

Subsection 50-6-239(c)(8) permits a workers’ compensation judge to “assess

discretionary costs including reasonable fees for depositions of medical experts

against the employer.” Further, as Central Sales argued, the Appeals Board reduced

an award of costs “incurred in the pursuit of permanent total disability benefits,”

which claim was unsuccessful. Oldham v. Freeman Webb Co. Realtors, 2024 TN

Wrk. Comp. App. Bd. LEXIS 37, at *42 n.9 (Nov. 8, 2024).

Mr. Primm’s claims for permanent total disability or 12% permanent partial

disability were unsuccessful. So, costs for Dr. Standard’s deposition are not

available. However, the remainder of the requested costs, $995.00, is reasonable

and awarded to him.

12

IT IS, THEREFORE, ORDERED as follows:

1. The Subsequent Injury and Vocational Recovery Fund is dismissed from this

case with prejudice.

2. Central Sales shall pay Mr. Primm permanent partial disability benefits of

$15,303.02. Mr. Primm may file another petition seeking increased

permanent partial disability under section 50-6-207(B).

3. Central Sales shall pay Mr. Primm $13,463.87 in a lump-sum as past

temporary disability benefits.

4. Central Sales shall furnish reasonable, necessary, and work-related future

medical benefits with Dr. Standard under section 50-6-204.

5. Mr. Primm’s counsel is entitled to attorney fees of 20% of his past disability

and original awards.

6. Central Sales shall pay Mr. Primm’s discretionary costs of $995.00.

7. The Court taxes the $150.00 filing fee to Central Sales, to be paid to the Court

Clerk under Tennessee Compilation Rules and Regulations 0800-02-21-.06

(2026) within five business days, and for which execution might issue.

8. Central Sales shall file a Statistical Data Form (SD-2) with the Court Clerk

within ten days of the date this order becomes final.

9. Unless appealed, this order becomes final 30 days after entry.

ENTERED June 24, 2026.

JUDGE KENNETH M. SWITZER

Court of Workers’ Compensation Claims

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APPENDIX

Exhibits:

1. Deposition of Dr. Scott Standard with exhibits

2. Deposition of Dr. John Brophy with exhibits, and videotape

3. Joint Medical Records for Compensation Hearing

4. Affidavit for Attorney Fee of Charles L. Hicks

5. Bank statements, December 31, 2024, February 28, 2025

6. Answers to Requests for Admissions, p. 1

7. Answers to Request for Production, p. 4

8. Answers to Interrogatories, p. 3

9. Mr. Primm’s Facebook post, April 8, 2025

10.Google review of Primm Powder Coating by Terry LeFrain

11.Mr. Primm’s Facebook post, March 24, 2026

12. Mr. Primm’s Facebook post (late-filed), April 17, 2026

13.Mileage reimbursement, May 15, 2026

14.Three Rivers Hospital record, October 21, 2017

15. Dickson Medical Associates record, February 23, 2017

16.Cleat Department Supervisor job description

17.Excerpts from the AMA Guides

CERTIFICATE OF SERVICE

I certify that a copy of this Order was sent as indicated on June 24, 2026.

Name Email Sent to

Larry Hicks, employee’s attorney X Office@hickslawfirm.com

Ben Norris, employer’s attorney X Bnorris@eraclides.com

Laurenn Disspayne, SIF attorney X Laurenn.Disspayne@tn.gov

Penny Shrum

Clerk, Court of Workers’ Compensation Claims

WC.CourtClerk@tn.gov

14

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 -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]

LB-1099 rev. 01/20 Page 2 of 2 RDA 11082