The Supreme Court of Tennessee reversed a trial court’s denial of a motion to dismiss an employee’s claim for workers compensation benefits stemming from her employer’s failure to use its automated external defibrillator when she collapsed.

In Chaney v. Team Technologies Inc., the state’s high court held Thursday in Knoxville that the employer had no duty to use its AED to assist the employee in a medical emergency and was not liable for workers comp benefits.

In March 2013, the employee of Team Technologies Inc. in Morristown, Tennessee, collapsed at work because of a medical condition unrelated to her employment. Her heart stopped beating and she could no longer breathe. The employer called for medical assistance, but did not use the AED it had acquired to assist her. Medical responders revived the employee, but she suffered a permanent brain injury caused by oxygen deprivation.

In January 2015, she sued Team Technologies, seeking workers comp benefits for injuries that allegedly resulted from her employer’s failure to use its AED. She claimed that its failure to use the AED and train or hire an employee able to use the technology delayed resuscitation efforts and caused her to sustain the brain injury. Team Technologies moved to dismiss her complaint on the grounds that her injury was unrelated to her employment and that an employer had no statutory or common law duty to use an acquired AED.

A trial court denied Team Technologies motion, but granted its motion to seek an interlocutory appeal. The Tennessee Supreme Court reversed the trial court’s decision and remanded the case for dismissal. In making its decision, the court revisited its 1977 holding in Vanderbilt University v. Russell, which adopted an “emergency rule” after finding that Tennessee's Workers' Compensation Law is a remedy for a disability that results in an employer’s failure to render aid to an employee who has suffered an illness or injury in the course of, but not arising out of, employment.

The court held that there is no dispute that the employee’s injury occurred in the course of her employment and that the employer had a duty to provide reasonable medical assistance. However, the court noted that the emergency rule requires an employer to render “reasonable” assistance, not “any and all medical assistance.”

While the employee argued that the court should extend its holding of the emergency rule to require an employer to use an acquired AED, the court noted that Tennessee’s AED statutes — while encouraging businesses to acquire AEDs — do not require companies to purchase them or use the AEDs if acquired.

The court reversed the trial court’s denial of Team Technologies motion to dismiss and remanded the case for an order of dismissal. The court also assessed the cost of the appeal to the employee.

Team Technologies declined to comment on the case.