They filled his role while he healed – what came next cost them
Coca-Cola Consolidated must pay a resulting award after offering an injured 30-year employee only lower-paying roles when he returned to work.
A Tennessee workers' compensation court ruled on March 30, 2026, that Coca-Cola Consolidated, Inc. owes employee Harlan Paul Matteson, Jr. a resulting award of $19,987.56 – a decision that underscores the financial consequences employers can face when return-to-work placements fall short.
Matteson hurt his right shoulder on the job. Coca-Cola accepted the claim, and he received authorized medical treatment from Dr. David Hovis, who assigned a 6% rating and cleared him for full duty on May 23, 2024. So far, a textbook workers' compensation case.
The problem started when Matteson came back. While he was out, Coca-Cola had filled his position. Rather than restoring him to an equivalent role, the company gave him two options – both paying less than what he earned before the injury. He took one of them.
Under Tennessee law, when an employee returns to work earning less than pre-injury pay, that employee can petition for increased benefits. The statute allows the original award to be multiplied by 1.35, with an additional 1.2 multiplier for workers over 40. Matteson is 50.
Coca-Cola pushed back, arguing that these increased benefits are not automatic. The company pointed to the statutory language "if appropriate" and contended that Matteson's pay cut had nothing to do with his injury. After all, he was released to full duty. The employer also argued that Matteson never tried to find comparable pay elsewhere, and that the court should weigh that against him.
Judge Lisa A. Lowe agreed with Coca-Cola that benefits under the statute are not automatic. However, applying a framework set by the state's Appeals Board, which directs trial courts to examine the full picture – the reasonableness of the employee's return, the worker's willingness and ability to work despite a disability, and the employer's efforts to bring the injured worker back – the judge found that increased benefits were appropriate in this case.
What tipped the scales was Matteson's 30-year career at Coca-Cola. The court found it entirely reasonable that a worker with three decades of tenure would stay put rather than start over at a new company, even if another job might match his old pay. Walking away would have meant losing access to employment benefits accumulated over a career – a trade-off the court recognized as a legitimate factor.
The court also noted that the cases Coca-Cola cited in its defense involved different circumstances: employers that offered injured workers the same pay, only for the employee to refuse. That was not what happened here. Coca-Cola offered less, and Matteson accepted what was available.
On attorney fees, the court found that Coca-Cola's failure to pay the resulting award was not unreasonable, given that the statute requires a case-by-case analysis rather than automatic payment. The employer was therefore not ordered to cover the employee's legal costs. Matteson's attorney will instead collect 20% of the resulting award as fees. Coca-Cola was also ordered to pay a $150 filing fee.
The order becomes final in 30 calendar days unless appealed to the Workers' Compensation Appeals Board.
For HR professionals, the case is a pointed reminder that return-to-work planning does not end when an employee is medically cleared. What role you bring them back to – and at what pay – can trigger additional financial exposure under workers' compensation statutes. Filling an injured worker's position during leave without a clear reinstatement plan is a decision that carries measurable risk, as Coca-Cola Consolidated just found out.
The case is Matteson v. Coca-Cola Consolidated, Inc., Docket No. 2024-30-3105 (Tenn. Ct. Workers' Comp. Claims, Mar. 30, 2026).
