Tennessee Court Rejects Hospital Worker’s Mental Injury Claim for Late Notice

A recent ruling from the Tennessee Court of Workers’ Compensation Claims offers an instructive case for adjusters handling mental injury claims. In this instance, a hospital employee’s failure to follow procedural notice requirements resulted in a complete dismissal of her claim for alleged psychological injuries. The worker cited three specific workplace incidents in April 2023 as the cause of her symptoms but failed to report them via the employer’s designated internal system or in any written form.

The employer, HCA Health Services of Tennessee, successfully argued for summary judgment on the basis that there was no genuine dispute regarding the lack of notice. Importantly, the judge emphasized that Tennessee law requires immediate or reasonably prompt written notice of such injuries—standards the claimant did not meet. The worker’s absence at the hearing and failure to respond to the employer’s motion further supported the court’s decision.

For adjusters, this case reinforces the critical importance of timely documentation and procedural compliance in mental injury cases, which are often more subjective and harder to substantiate. It also highlights the evidentiary burden on employers and the need for documented systems for injury reporting, especially when claims involve non-physical injuries.