Timmy Dale Britt v. Dyer's Employment Agency, Inc., 396 S.W.3d 519

Dyer's Employment Agency employed Britt as a temporary worker assigned to Mark IV, a manufacturer.
Britt sustained a compensable right-arm injury three weeks into his assignment and was treated; surgery for carpal tunnel was performed on January 9, 2009, with a 4% impairment rating.
Mark IV advised the assignment had ended; Dyer's terminated Britt's employment consistent with its practice and did not return him to work.
Trial court awarded benefits but capped them at 1.5 times Britt's impairment under §50-6-241(d)(1)(A), despite medical impairment of 4%.
SWCAP vacated and remanded to determine if Britt had a meaningful return to work; the issue centered on which multiplier applies when no return or offer occurred.
The Tennessee Supreme Court held that because Britt was not returned to work, offered a return, or terminated for misconduct, the greater multiplier (up to six times impairment) applies and remanded for appropriate award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Which multiplier governs?	Britt sought the greater cap (6x) since no return to work occurred.	Dyer's argued the lesser cap (1.5x) should apply when employment is temporary.	Greater multiplier applies; up to six times impairment.
Does the concept of meaningful return to work apply where there was no return or offer?	Meaningful return to work should inform the multiplier.	Meaningful return to work is not applicable here due to lack of return/offer.	Meaningful return to work has no application when the employer did not return or offer work.
Should the trial court have considered temporary nature or employer practices in applying the multiplier?	Trial court can consider business practices and temporary nature to justify a lesser cap.	Statutory language governs; no exception for temporary placement practices.	Statutory language controls; no exception for temporary-employment practices.

Tryon v. Saturn Corp., 254 S.W.3d 321 (Tenn. 2008) (meaningful return to work framework for multiplier decisions)
Carter v. First Source Furniture Grp., 92 S.W.3d 367 (Tenn. 2002) (firing for misconduct before treatment not required to gain lower cap)
Williamson v. Baptist Hosp. of Cocke Cnty., Inc., 361 S.W.3d 483 (Tenn. 2012) (history and structure of multiplier caps; statutory framework)
Lynch v. City of Jellico, 205 S.W.3d 384 (Tenn. 2006) (general purpose of workers’ compensation statutes)
Gerdau Ameristeel, Inc. v. Ratliff, 368 S.W.3d 503 (Tenn. 2012) (guidance on remand and appellate review in workers’ comp cases)