Employer's Subrogation Lien Cannot Include Case Management Service Fees

In a case of first impression, the Tennessee Court of Appeals ruled that nurse case management fees are not recoverable as part of an employer’s workers’ compensation subrogation lien. Case: Memphis Light, Gas and Water Division v. Watson, No. W2018-00218-COA-R3-CV, 02/13/2019, published. Facts and procedural history: Tykena Watson worked for the Memphis Light, Gas and Water Division as a meter reader. She suffered injuries when she was attacked by a dog in June 2013. MLGW provided workers' compensation benefits to Watson after the attack and eventually settled wit...