A Tennessee appellate court on Friday revived a premises liability lawsuit that hinges on the limits of workers compensation immunity, ruling that a tractor supply company cannot avoid trial after the state Supreme Court determined the retailer was not the injured worker’s statutory employer.
The Court of Appeals of Tennessee vacated summary judgment in favor of Tractor Supply and remanded the case for further proceedings in Brian Coblentz v. Tractor Supply Company.
The case stems from a 2012 incident in which Brian Coblentz, an outside sales representative for Stanley National Hardware, was struck in the head by a 12-foot steel barn door track that fell from a display rack inside a Tractor Supply store in Fayetteville. Mr. Coblentz settled his workers compensation claim with his direct employer before pursuing a negligence suit against the retailer.
Initially, lower courts sided with Tractor Supply, finding it qualified as Coblentz’s “statutory employer” under Tennessee law and was therefore shielded by the exclusive remedy provision of the Workers’ Compensation Act. But in 2025, the Tennessee Supreme Court reversed, holding that a vendor-vendee relationship does not make a retailer a statutory employer.
On remand, the Court of Appeals addressed whether the negligence claim could proceed. The panel concluded that genuine issues of material fact remain regarding whether Tractor Supply had constructive notice that a required safety bar on the display may have been missing and whether the risk of harm was foreseeable.
The court emphasized that even when a hazard may be considered “open and obvious,” Tennessee law requires a full duty analysis balancing foreseeability and the burden of prevention before dismissing a claim.
The case now returns to the trial court for further proceedings.
