William H. Mansell v. Bridgestone Firestone North American Tire, LLC, 417 S.W.3d 393

In 2008, Mansell injured his right shoulder while employed by Bridgestone Firestone; doctors issued impairment ratings of 3% and 10%.
The MIR process under Tenn. Code Ann. § 50-6-204(d)(5) was requested before trial; trial court quashed it, citing lack of waiver and lack of jurisdiction, and the case proceeded to trial without an MIR report.
After trial, the court awarded benefits using the 10% rating from Dr. Landsberg, and found the MIR process unconstitutional as applied.
On appeal, the Tennessee Supreme Court vacated and remanded to address the constitutional challenges, adding the Attorney General as a defendant.
On remand, Mansell submitted to an MIR by Dr. Weisman (7%), and the trial court again questioned the MIR statute’s constitutionality.
The Supreme Court held the MIR process constitutional, determined the 7% MIR rating should govern, and remanded to modify the award to 1.5 times the 7% rating.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the MIR statute constitutional as applied in court?	Mansell: separation of powers prohibits MIR; presumption impairs judicial function.	Bridgestone/State: MIR is constitutional and aids efficient adjudication; evidenced-based.	Constitutional; MIR does not impermissibly infringe judicial power.
Does the MIR presumption violate due process?	Presumption is irrebuttable in practice, denying meaningful opportunity to contest impairment.	Presumption is rebuttable by clear and convincing evidence; not a permanent irrebuttable presumption.	Presumption is rebuttable and does not violate due process.
May the trial court properly apply the MIR presumption to override conflicting evidence?	Trial court may overcome MIR rating with clear and convincing evidence.	Evidence must clearly and convincingly rebut the MIR presumption; weighing is limited.	Record did not show clear and convincing rebuttal; 7% rating stands.
Is the MIR process properly interpretable as applicable in court, not only DOL?	MIR applies only to DOL proceedings.	MIR applies wherever a dispute exists, including court; statutory language broad.	MIR applies in court; statutory interpretation favors broad applicability.

Mallard v. State, 40 S.W.3d 473 (Tenn. 2001) (court may interpret statutes supplementally, avoiding encroachment on judicial power)
Martin v. Lear Corp., 90 S.W.3d 626 (Tenn. 2002) (upholds restricted expert testimony in workers’ compensation context; choice of policy by legislature)
Colonial Pipeline Co. v. Morgan, 263 S.W.3d 827 (Tenn. 2008) (statutory interpretation; framework for applying statutes to statutory schemes)
Scott v. Nashville Bridge Co., 223 S.W.2d 844 (Tenn. 1920) (historic validation of workers’ compensation act; legislative authority)