Tennessee’s highest court has clarified the state’s workers' compensation law, holding property owners cannot avoid tort liability to employees of vendors injured on their premises. In an opinion issued on December 22, 2025, the Tennessee Supreme Court vacated a trial court’s entry of summary judgment against Plaintiffs Brian and Cayce Coblentz, who were represented on appeal by Thompson Burton.

Mr. Coblentz was an outside sales representative for Stanley National Hardware. He serviced Stanley product displays at Tractor Supply locations in his region by checking inventory, writing orders, and tidying and maintaining product placement. While at Tractor Supply’s Fayetteville, Tennessee store in 2012, a barn door track from a Stanley display fell and struck him, causing serious injuries. Mr.Coblentz received workers’ compensation benefits from Stanley National. Mr.Coblentz and his wife filed suit alleging Tractor Supply was negligent in its maintenance of the Stanley display. The plaintiffs pointed out that the barn door tracks had fallen out of the same display and hit other people in the past.

Under Tennessee Code Annotated section 50-6-113, the responsibility for paying workers' compensation benefits to injured employees extends beyond the traditional employer-employee relationship to contractors and subcontractors. In exchange for that added protection for employees, the “exclusive remedy” provision inthe Workers Compensation Act shields these “statutory employers” from tort liability. Tractor Supply contended that Stanley National was a subcontractor and that Tractor Supply was Mr. Coblentz’s “statutory employer” and was therefore shielded from liability.

The trial court agreed and granted summary judgment to Tractor Supply. A majority of the panel of the Tennessee Court of Appeals affirmed the trial court’s decision. The Tennessee Supreme Court granted the Coblentz’s petition for review. The question before the Supreme Court was whether, in a typical vendor-vendee relationship, the vendee may claim the benefit of the “exclusive remedy” in the Workers Compensation Act as the “statutory employer” of the vendor’s employee if that employee is injured on the vendee’s premises.  

The Supreme Court reversed the lower courts’ decisions and ruled in favor of Mr. and Ms. Coblentz, holding the term “subcontractor” in § 50-6-113(a) refers to an entity that performs labor or services for another and does not encompass a pure vendor engaged in the sale and ancillary delivery of goods. Consequently, a vendor-vendee relationship is outside § 50-6-113(a), and the vendee is not transformed into a statutory employer with tort immunity solely by virtue of purchasing and receiving products. The Court grounded its analysis in the statutory text and historical usage at the time of enactment of the Workers Compensation Act, noting that contemporaneous dictionaries defined “subcontract” and “subcontractor” in terms tied to the performance of work, not the sale of goods.

Recognizing that some sales arrangements include service components beyond delivery, the Court adopted a tailored “predominant purpose” test—drawn from Uniform Commercial Code cases—to distinguish transactions that are predominantly for the sale of goods from genuine services subcontracts for purposes of §50-6-113. In applying that test, lower courts must consider the totality of the parties’ dealings, focusing on whether services are incidental to the sale of goods or whether the contract includes an undertaking to render substantial services. The written contract does not control the outcome; instead, the analysis looks to the course of performance, the nature of each party’s business, what was bargained for, and how the transaction was priced. If goods predominate and services are incidental, the relationship remains vendor-vendee and falls outside § 50-6-113; only if services predominate does the “statutory employer” analysis apply.

Applying the predominant purpose test to the case at hand, the Court found the Tractor Supply–Stanley agreement to be predominantly for the sale of goods. Considering the totality of circumstances, the Court concluded the relationship was not that of principal contractor and subcontractor, and Tractor Supply therefore was not Mr. Coblentz’s statutory employer. Because § 50-6-113 did not apply, Tractor Supply could not claim the Workers’ Compensation Act’s exclusive remedy to bar Plaintiffs’ tort claims.

Rick Colbert argued the case before the Tennessee Supreme Court in February 2025. Colbert is a veteran appellate advocate who has argued before the United States Supreme Court and has handled numerous appeals before the federal courts of appeals as well as the Tennessee Supreme Court and Court of Appeals. On brief was Sarah Ingalls,a member of Thompson Burton’s appellate practice group. Colbert and Ingalls worked on the case with Will Hicky of Nashville, who represented the Plaintiffs in the trial court. To read more about the appeals handled by Thompson Burton attorneys across state and federal courts, visit our appellate practice group page.

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