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Law School Case Brief

Vaughn v. Shelby Williams of Tenn., Inc. - 813 S.W.2d 132 (Tenn. 1991)

Rule:

Where a trial court bases its decision in a workmen's compensation action on facts, not contained in record but acquired by the trial court's extrajudicial observation of the claimant, that constitutes reversible error.

Facts:

Claimant employee suffered a work-related back injury that required him to undergo surgery. The employee filed a claim for workmen's compensation benefits and alleged that he suffered temporary and permanent disability. The claimant presented evidence from a doctor assessing the employee's impairment rating at 25 percent. The trial court awarded the employee 80 percent permanent partial disability to the body as a whole plus temporary total disability benefits. The trial court based its award on the medical and vocational proof and the trial judge's observation of the employee on three separate occasions unrelated to the trial. The employer sought review and argued that the trial court erred in considering evidence that was not presented at trial.

Issue:

Did the trial judge err in considering evidence that was not presented at trial from where it based its decision to award employee 80 percent permanent partial disability to the body as a whole plus temporary total disability benefits?

Answer:

Yes.

Conclusion:

The Court held that a judge may not formulate a decision based upon information obtained outside the course of the judicial proceedings before him, even though the judge may not have intended to learn of the facts pertinent to the case. In the instant case, the trial court's personal observations played a significant role in the exercise of judicial discretion in arriving at an award of benefits. In doing so, the court committed reversible error.

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