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Law School Case Brief

Yardley v. Hosp. Housekeeping Sys., LLC - 470 S.W.3d 800 (Tenn. 2015)

Rule:

Workers' compensation laws necessarily interact with the State's employment laws. Tennessee recognizes the employment-at-will doctrine as the fundamental principle controlling the relationship between employers and employees. Under this doctrine, either the employer or the employee may terminate the employment relationship with or without cause. An employer's ability to make and act upon independent assessments of an employee's abilities and job performance as well as business needs is essential to the free-enterprise system. Thus, the doctrine recognizes that employers need the freedom to make their own business judgments without interference from the courts. Both job applicants and prospective employers may freely choose whether to enter into the employer-employee relationship.

Facts:

Plaintiff Yardley sued the defendant Hospital Housekeeping Systems, LLC, when the company refused to hire the job applicant Yardley based on the probability that she would file a Worker’s Compensation Claim. The Supreme Court of Tennessee accepted a certified question to determine whether a job applicant has a cause of action under the Tennessee Workers' Compensation Act against a prospective employer for failure to hire if the prospective employer failed to hire the job applicant because that applicant had filed, or is likely to file, a workers' compensation claim against a previous employer.

Issue:

Does the job applicant have a cause of action for failure to hire under the Tennessee Workers' Compensation Act?

Answer:

No.

Conclusion:

The Court held that a job applicant did not have a cause of action under the Tennessee Workers' Compensation Act against a prospective employer for failure to hire a job applicant because that applicant had filed, or was likely to file, a workers' compensation claim against a previous employer. -Under Tenn. Code Ann. § 50-6-102(11)(A), the job applicant was not an employee, and the Act applied to employers and employees only.

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