Melissa Binns v. Trader Joe's East, Inc.

This case addresses whether the Uniform Arbitration Act confers subject matter jurisdiction on Tennessee courts to confirm an arbitration award when the parties' arbitration agreement specified that arbitration would occur in another state. Berkeley Research Group, LLC and Southern Advanced Materials, LLC entered into a contract which provided that any dispute would be resolved by arbitration in Pennsylvania, not Tennessee. A dispute arose and the parties entered arbitration, which resulted in an award to Berkeley. Berkeley sought to confirm the arbitration award in Shelby County Chancery Court. The trial court confirmed Berkeley's arbitration award and entered judgment. The Court of Appeals reversed, finding that while the trial court had subject matter jurisdiction, it lacked personal jurisdiction over Southern. We find that Tennessee courts lack subject matter jurisdiction to confirm an arbitration reward when the parties agreed arbitration would occur in another state. As a result, the trial court lacked jurisdiction to confirm an award resulting from an arbitration the parties agreed would occur in Pennsylvania. We vacate the judgments of the lower courts and dismiss the petition to confirm the award.

Belinda LeMaire ("Employee") sustained an injury to her right foot while working forLowe's Home Centers, LLC ("Employer"). The claim was accepted as compensable, andthe Court of Workers' Compensation Claims ("trial court") entered a compensation orderawarding permanent-partial disability benefits along with future reasonable and necessaryrnedical benefits. Employee subsequently filed a petition for benefit determination statingthat she had been discharged by her treating physician, and Employer was refusing toprovide additional medical treatment. Following a hearing, the trial court ordered Employerto provide Employee with a new panel of physicians qualified and willing to treat her workrelatedinjury. The Workers' Compensation Appeals Board ("Appeals l3oard") affirmed.Employer has appealed and the appeal has been referred to the Special Workers'Compensation Appeals Panel pursuant to Tennessee Supreme Court Rule 51. We affirmthe judgment of the Appeals Board and adopt its opinion as set forth in the attachedAppendix.

Lauren Taylor ("Employee") sustained a compensable injury on May 12, 2019, whileworking for John and Stephanie Ingram, LLC ("Employer"). The Court of Workers'Compensation Claims ("trial court") entered an order approving a settlement agreement onAugust 24, 2021. Giving rise to the instant appeal, Employee filed a motion to set aside thesettlement agreement on January 24, 2024. The trial court denied the motion on twoindependent grounds. First, the trial court determined that the motion was not timely filed.Second, the trial court found that, even if the motion was timely, Employee had failed toshow that relief was warranted. The Workers' Compensation Appeals Board ("AppealsBoard") affirmed on both grounds. Employee has appealed and the appeal has been referredto the Special Workers' Compensation Appeals Panel pursuant to Tennessee SupremeCourt Rule 51. We affirm.

Mark Gray ("Employee") reported injuries after falling from a ladder while working for Tyson Foods, Inc. ("Employer"). The claim was accepted as compensable, and the parties entered into a settlement agreement providing permanent partial disability benefits. After the initial compensation period ended, Employee filed a petition for increased benefits. Following a hearing, the Court of Workers' Compensation Claims ("trial court") denied the request for increased benefits. The Workers' Compensation Appeals Board ("Appeals Board") affirmed. Employee has appealed, and the appeal has been referred to the Special Workers' Compensation Appeals Panel pursuant to Tennessee Supreme Court Rule 51. We affirm the judgment of the Appeals Board and adopt its opinion as set forth in the attached Appendix.

I concur fully in the majority opinion. I write separately only to elaborate on the admissibility of extrinsic evidence, versus how it may be used. The extrinsic evidence at issue in this case is Mr. Smith's deposition testimony. During the deposition, the State's counsel asked Mr. Smith whether it was his "understanding that it was within Pharma's ability and Pharma's sole determination to decide what conferences were feasible to produce?" Mr. Smith responded, "Yes." Discussing this evidence, the majority opinion says that evidence of "a party's subjective views on the contract's meaning . . . should not be considered."