The Tennessee Workers Compensation Appeals Board on Thursday reversed an award of additional temporary disability benefits to a Topgolf bartender who sought benefits after a second doctor recommended knee surgery.
In Jayne-Anne Patrick v. Topgolf, the board affirmed in part, reversed in part and remanded a ruling by the Court of Workers’ Compensation Claims. Ms. Patrick injured her left knee on June 1, 2024, when she slipped on a wet floor while restocking a beer cooler. Topgolf accepted the claim as compensable and paid some medical and temporary disability benefits.
Ms. Patrick underwent surgery for a torn meniscus in January 2025. Her treating physician placed her at maximum medical improvement in June 2025 with a 1% impairment rating and no restrictions, and Topgolf ended temporary disability benefits.
A later physician recommended revision knee arthroscopy, and the trial court awarded additional temporary disability benefits beginning on the date of that recommendation.
The appeals board reversed that portion of the ruling, holding that a recommendation for more treatment does not, by itself, undo an earlier MMI finding. To receive additional temporary disability benefits after MMI, the worker needed medical evidence showing the original MMI determination was premature or should be retracted, the board said.
The board affirmed the order requiring Topgolf to provide additional medical treatment it had agreed to provide.