Gerdau Ameristeel, Inc. v. Steven Ratliff, 368 S.W.3d 503

Ratliff worked as a melt shop attendant for Ameristeel; February 2008 coworker died at the plant.
April 2008 another coworker died at a different plant area; Ratliff witnessed the scene.
Ratliff developed anxiety and PTSD symptoms following the two incidents; diagnosis occurred June 23, 2008.
Ratliff requested a benefit review conference on June 23, 2009; Ameristeel filed a workers’ compensation benefit amount action and a summary judgment motion.
Trial court granted summary judgment, holding the claim barred by the statute of limitations beginning April 4, 2008.
Court reversed, holding the limitations period tolls until discovery of the compensable injury and awarding 20% permanent partial disability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether discovery rule tolls the limitations period	Ratliff argues discovery rule applies to §50-6-203(b)(1).	Ameristeel asserts limitations begin at accident date; discovery rule does not apply post-2004 amendment.	Discovery rule applies; not barred by statute of limitations.

Griffitts v. Humphrey, 288 S.W.2d 1 (Tenn. 1955) (distinguishes accrual times for 203(b)(1) and 224(a)(1))
Ogle v. Tennessee Eastman Corp., 206 S.W.2d 909 (Tenn. 1947) (injury accrual upon discovery of disability)
Threadgill v. Lexington Metal Prods. Co., 632 S.W.2d 550 (Tenn. 1982) (discovery rule applicable to 203(b)(1))
Norton Co. v. Coffin, 553 S.W.2d 751 (Tenn. 1977) (diagnosis date triggers accrual)
Union Carbide Corp. v. Cannon, 523 S.W.2d 360 (Tenn. 1975) (discovery of compensable injury tolled statute)
Reed v. Genseco, Inc., 512 S.W.2d 1 (Tenn. 1974) (discovery-based tolling for compensable injury)
Imperial Shirt Corp. v. Jenkins, 399 S.W.2d 757 (Tenn. 1966) (discovery of connection to injury tolls statute)
Livingston v. Shelby Williams Indus., Inc., 811 S.W.2d 511 (Tenn. 1991) (statute tolling when compensable injury becomes apparent)