Why one employer avoided paying for a worker's leg treatment after surgery
A swollen, aching leg after knee surgery. A Tennessee court just told the employer it need not pay for the treatment – at least not yet.
On August 15, 2023, Christina Manus Henry injured her left knee while working for Fitzgerald Collision & Repair. She got authorized care, saw an orthopedist, and underwent a knee replacement. After the operation, she struggled with leg pain, swelling, and spasms she had never had before.
Her orthopedist referred her to a vascular specialist, Dr. Sina Iranmanesh, and the employer authorized the visit. Testing found severe reflux running the full length of a major leg vein, and the doctor diagnosed venous insufficiency – a condition where the leg veins struggle to push blood back toward the heart.
That is where the claim ran into trouble. According to the order, the specialist said the vein problem had likely been present for many years, meaning it predated the workplace injury. He noted that because Henry had been relatively free of symptoms until after her surgery, it was reasonable to think something had brought those symptoms to the surface. Even so, he did not believe the condition was a direct result or complication of her surgery.
The medical picture then shifted with each letter. After the employer declined to authorize treatment, Henry's attorney asked the doctor whether her injury or surgery had made the condition symptomatic. He marked yes, and also yes when asked whether the anatomical changes to her leg from the injury and surgery had aggravated it. But when the employer's side followed up for clarification, the doctor agreed that Henry's preexisting conditions, not her 2023 work injury, accounted for more than 50% of the cause. As the order describes it, he explained that the venous insufficiency was likely present before the injury and surgery.
That 50% line is the heart of the case for anyone managing comp claims. Under Tennessee law, an employer can still be liable for aggravating a condition a worker already had – but only if the work accident caused more than half of that aggravation. In his June 5, 2026 order, Judge Robert Durham relied on the state Supreme Court's recent ruling in Edwards v. Peoplease, LLC to spell out a two-part test: the work accident must have contributed more than 50% to the aggravation, and the aggravation must have contributed more than 50% to the disability or the need for treatment.
The doctor's records, the court found, answered neither question. They did not show that the work injury drove more than half the aggravation, or that any aggravation drove more than half the need for care. On that basis, Judge Durham held that Henry had not shown she was likely to win on causation, and he denied her request for further treatment for now.
For HR teams and comp administrators, the takeaway is about paperwork, not sympathy. A treating physician ticking yes on a questionnaire does not carry a claim. The causation opinion has to hit the legal standard head-on – those more-than-50% thresholds – or the claim built on it can collapse. And this one is not finished: the order is interlocutory, a status conference is set for July 1, 2026, and Henry can still appeal.
The case is Christina Manus Henry v. Fitzgerald Collision & Repair, LLC, Docket No. 2025-40-3091, decided by Judge Robert Durham of the Tennessee Court of Workers' Compensation Claims on June 5, 2026.
