Anderson v. Save-A-Lot, Ltd.

The plaintiff was the co-manager of a Save-A-Lot grocery store in Memphis, where her immediate supervisor sexually harassed her daily and threatened to kill her if she reported the harassment. She reported him and transferred to another store, but suffered post-traumatic stress disorder (“PTSD”) and other psychological problems for which she sought medical treatment. She filed a complaint for workers compensation, which is at issue in this appeal, as well as a claim in federal court for sexual harassment in violation of the Tennessee Human Rights Act (“THRA”) and Title VII of the Civil Rights Act of 1964. The Shelby County Chancery Court granted summary judgment in favor of her employer on her worker’s compensation claim, finding that that her injuries did not arise out of her employment. The Special Workers Compensation Appeals Panel reversed and remanded, but the Supreme Court of Tennessee reversed the Panel’s ruling, holding that her employment was not the “but for” cause of her injuries.