Tennessee judge backs employer that suspended workers' comp benefits over missed appointments

A missed deposition was the last straw – here's how the staffing firm built its case

Tennessee judge backs employer that suspended workers' comp benefits over missed appointments

A Tennessee staffing firm has kept workers' comp benefits switched off after an injured employee skipped treatment and went silent on his own lawyer.

In an expedited hearing order filed May 15, 2026, Judge Lisa A. Lowe of the Tennessee Court of Workers' Compensation Claims sided with Labor Finders of Tennessee, denying Stephen Eiland's request to restart temporary disability payments. The judge did order the company to authorize one more visit with Eiland's treating doctor to reassess what treatment, if any, he currently needs.

The injury came from a roadside crash. Eiland was a passenger in a box truck delivering windows when the driver struck a guardrail at roughly 55 to 60 miles per hour. He reported a neck injury. Labor Finders accepted the claim and authorized treatment with orthopedic physician Dr. Patrick Bolt, who set lifting and movement restrictions the company could not accommodate. The employer then paid temporary partial disability benefits.

Treatment ran through the usual conservative arc – physical therapy, then facet injections. Relief was short-lived. In October 2025, a nurse practitioner at Dr. Bolt's office recommended a medial branch block, with possible ablation to follow if the injection brought significant relief. Dr. Bolt signed off. After that, according to the order, Eiland produced no further medical records.

Labor Finders cut off temporary benefits on December 30, 2025, with a note in its records flagging that the claimant's whereabouts were unknown. The employer laid out a pattern. Eiland had completed only part of his prescribed physical therapy. He missed appointments with Dr. Bolt on July 15 and September 17. By December, his own attorney told the company he could not reach his client. A May 7 deposition went ahead without him.

Eiland testified that Labor Finders never contacted him about his location or his benefits.

The judge applied a section of Tennessee's workers' comp statute that suspends an injured employee's right to compensation while they refuse to comply with treatment. Lowe found that Eiland had been non-compliant with treatment, had not given the company an updated address, and had temporarily lost contact with his attorney. She ruled he was not likely to win back his temporary benefits.

For HR and workers' comp administrators, the order is a clean reminder that benefit suspensions hold up when the paper trail does. Labor Finders documented missed therapy sessions, no-shows with the authorized treating physician, a gap in medical records after October, and a lost-contact note from the employee's own counsel. That record decided the case.

The decision also marks the limits of suspension. The judge still required Labor Finders to send Eiland back to Dr. Bolt to determine what treatment, if any, is currently reasonable, necessary, and tied to the work injury. Medical authorization and wage-replacement benefits are separate questions, and a non-compliance finding on one does not close the door on the other.

A Status/Scheduling Hearing is set for August 18, 2026. The order is interlocutory and may be appealed within seven business days.

The case is Stephen Eiland v. Labor Finders of Tennessee and SUNZ Insurance Company, Docket No. 2026-30-0213, State File No. 20127-2025 (Tenn. Ct. of Workers' Compensation Claims, May 15, 2026).

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