Tennessee Code Annotated

Tenn. Code Ann. § 50-6-114 (2026)

Supremacy of chapter - Setoffs for payments by disability plan

✓ current as of May 2026

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(a) No contract or agreement, written or implied, or rule, regulation or other device, shall in any manner operate to relieve any employer, in whole or in part, of any obligation created by this chapter, except as provided in subsection (b).

(b) Any employer may set off from temporary total, temporary partial, permanent partial and permanent total disability benefits any payment made to an employee under an employer funded disability plan for the same injury; provided, that the disability plan permits such an offset. The offset from a disability plan may not result in an employee's receiving less than the employee would otherwise receive under this chapter. In the event that a collective bargaining agreement is in effect, this subsection (b) shall be subject to the agreement of both parties.

Acts 1919, ch. 123, § 16; Shan. Supp., § 3608a165; Code 1932, § 6867; T.C.A. (orig. ed.), § 50-916; Acts 1996, ch. 919, § 1.

Notes of Decisions

Cited in 64 cases (8 in the last 5 years), 1984–2026 · leading case: Nutt v. Champion Int'l Corp., 980 S.W.2d 365 (Tenn. 1998).

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Nutt v. Champion Int'l Corp., 980 S.W.2d 365 (Tenn. 1998). · cites it 16× “A 1996 amendment to Tenn. Code Ann. § 50-6-114 permits offsets against workers’ compensation benefits for payments made to an employee under an employer-funded disability plan.”

Anderson v. Stand. Register Co., 857 S.W.2d 555 (Tenn. 1993). · cites it 6× “The Court found that T.C.A. § 50-6-114 evidences a clear public policy that employees should be protected from having their employment *557 terminated for asserting a workers’ compensation claim.”

Hodges v. S.C. Toof & Co., 833 S.W.2d 896 (Tenn. 1992). · cites it 4× “The Court merely recognized that implicit within the provisions of T.C.A. § 50-6-114 a cause of action existed to prevent an employer from utilizing retaliatory discharge as a device to defeat the rights of an employee under the Worker's Compensation Law.”

Kighwaunda M. Yardley v. Hosp. Housekeeping Sys., LLC, 470 S.W.3d 800 (Tenn. 2015). · cites it 8× “” Tenn. Code Ann. § 50-6-114 (a). 3 Although an employer’s decision to fire an employee for filing a worker’s compensation claim has been held to be an unlawful device, Clanton, 677 S.”

Overman v. Altama Delta Corp., 193 S.W.3d 540 (Tenn. 2006). · cites it 36× “By its language, section 50-6-114 was clearly not intended to affect the judgments of courts of law.”

Clanton v. Cain-Sloan Co., 677 S.W.2d 441 (Tenn. 1984). · cites it 3× “Frampton is especially significant for Tennessee in that the Indiana statute prohibiting devices is all but identical to T.C.A., § 50-6-114. Nevertheless, even in *444 the absence of such language, similar results have been reached.”

McCaleb v. Saturn Corp., 910 S.W.2d 412 (Tenn. 1995). · cites it 2× “section 50-6-114 (1991 Repl.), being part of the Tennessee Workers’ Compensation Act, which was in full force and effect at the time the injury occurred, and which provides as follows: 50-6-114.”

Smith v. Bridgestone/Firestone, Inc., 2 S.W.3d 197 (Tenn. Ct. App. 1999). · cites it 4× “Whether or not such violation would be a “device” under Tennessee Code Annotated section 50-6-114 and be thus admissible in evidence in a retaliatory discharge case is not a question presented to the court in this appeal.”

Simpson v. Frontier Cmty. Credit Union, 810 S.W.2d 147 (Tenn. 1991). · cites it 2× “§ 50-916 [now T.C.A. § 50-6-114] clearly forbids [reduction] of compensation benefits.”

Beacon4, LLC v. I & L Investments, LLC, 514 S.W.3d 153 (Tenn. Ct. App. 2016). · cites it 2× “B. 875). We determine the PPA in general to have remedial aims in that it operates to effectuate the means by which those it was designed to protect may recover their already existing property and contractual rights in funds they have earned.”

Harney v. Meadowbrook Nursing Ctr., 784 S.W.2d 921 (Tenn. 1990). · cites it 4× “This Court ruled in Clanton that, “[A] cause of action for retaliatory discharge, although not explicitly created by the statute, [T.C.A. § 50-6-114], is necessary to enforce the duty of the employer, to secure the rights of the employee and to carry out the intention of the…”

State Auto. Mut. Ins. Co. v. Hurley, 31 S.W.3d 562 (Tenn. 2000). · cites it 8× “Hurley submits the following arguments to support the trial court’s order: 1) that State Auto is liable for the entire amount of Hurley’s medical bills because State Auto stipulated Hurley’s medical expenses were reasonable and necessary; ; 2) allowing State Auto to pay only the…”

Show all 64 citing cases →

— Tenn. Code Ann. § 50-6-114(a) — 13 cases

Overman v. Altama Delta Corp., 193 S.W.3d 540 (Tenn. 2006). “By its language, section 50-6-114 was clearly not intended to affect the judgments of courts of law.”

Nutt v. Champion Int'l Corp., 980 S.W.2d 365 (Tenn. 1998). “A 1996 amendment to Tenn. Code Ann. § 50-6-114 permits offsets against workers’ compensation benefits for payments made to an employee under an employer-funded disability plan.”

Kighwaunda M. Yardley v. Hosp. Housekeeping Sys., LLC, 470 S.W.3d 800 (Tenn. 2015). “” Tenn. Code Ann. § 50-6-114 (a). 3 Although an employer’s decision to fire an employee for filing a worker’s compensation claim has been held to be an unlawful device, Clanton, 677 S.”

Smith v. Bridgestone/Firestone, Inc., 2 S.W.3d 197 (Tenn. Ct. App. 1999). “Whether or not such violation would be a “device” under Tennessee Code Annotated section 50-6-114 and be thus admissible in evidence in a retaliatory discharge case is not a question presented to the court in this appeal.”

Frayser v. Dentsply Int'l, Inc., 78 S.W.3d 242 (Tenn. 2002).

— Tenn. Code Ann. § 50-6-114(b) — 6 cases

Cantrell v. Carrier Corp., 193 S.W.3d 467 (Tenn. 2006).

Wiliams, David v. Nissan North Am., Inc., 2016 TN WC 162 (Tenn. Ct. Work. Comp. Cl. 2016).

Findley, Jack v. Volswagen Grp. of Am., Inc., 2017 TN WC 152 (Tenn. Ct. Work. Comp. Cl. 2017).

Friend, Kenneth v. Staples Contract & Com., LLC, 2020 TN WC App. 11 (Tenn. Work. Comp. App. Bd. 2020).

— Tenn. Code Ann. § 50-6-114(e) — 1 case

Brown, Linda v. Nissan North Am., 2020 TN WC 78 (Tenn. Ct. Work. Comp. Cl. 2020).

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