Tennessee Supreme Court hears argument over whether vendors are "statutory employers" under workers' comp law

The Tennessee Supreme Court heard oral arguments February 12 on whether Tractor Supply Company should be treated as a "statutory employer" of a visiting sales representative injured inside one of its stores, a determination that turns on how the court interprets Tenn. Code § 50‑6‑113(a).

The dispute arises from a premises injury that Brian Koblenz suffered when barn‑door rails fell at a Tractor Supply in Fayetteville while he was working as a sales representative for Stanley National. Rick Colbert, counsel for the plaintiff‑appellant, told the court the long‑standing three‑factor Murray/Lindsey test does not fit a vendor–vendee relationship and urged the justices to analyze the relationship’s factual details rather than automatically treating the retail purchaser as a principal contractor.

Why it matters: the issue controls whether certain businesses can be held liable under Tennessee’s workers’ compensation statute for injuries to non‑employee vendors’ workers. If the court narrows or expands the statutory‑employer rule, large numbers of delivery drivers, route…