TN Sup Crt: OK to Combine Injuries in Disability Rating

The Supreme Court of Tennessee Special Workers' Compensation Appeals Panel ruled that a trial court is not required to assess two injuries separately in determining a claimant's disability rating. In Byrge v. Zurich Servs. Corp. , No. E2004-00624-WC-R3-CV, 01/14/2005, Claimant fell on a concrete floor at work, thereby injuring his arm and leg. Claimant eventually needed surgery on both his arm and his leg, and at trial claimed pain generally, and specifically in his fingers and knee. Medical testimony established a 2% impairment rating to the leg and a 38% impairment rating to the right a...