The Tennessee Supreme Court has reversed a lower court ruling that granted disability pension benefits to a Chattanooga firefighter diagnosed with post-traumatic stress disorder (PTSD). The case centered on whether the firefighter’s traumatic experiences were “unexpected” within the meaning of the city’s pension policy.

Matthew Long served with the Chattanooga Fire Department for fifteen years before applying for disability retirement based on PTSD. His application cited several traumatic incidents, including fatal vehicle crashes involving children, a deadly apartment fire, and an encounter with an armed man while on a medical call.

Under the Chattanooga Fire and Police Pension Fund’s Disability Benefit Policy, firefighters seeking a job-related disability pension for a mental health disorder must show that their condition resulted from a “traumatic event that is identifiable, undesigned, and unexpected.” This “unexpected” requirement is critical because the policy limits coverage to mental health disabilities arising from traumatic events that go beyond what a firefighter could reasonably anticipate as part of the job.

The Chattanooga Fire and Police Pension Fund Board of Trustees denied the claim, finding that the events, while tragic, were not “unexpected” given the nature of firefighting duties. Long sought judicial review, arguing that the Board’s decision was arbitrary and unsupported by evidence. The trial court reversed the denial, holding that the pension policy was ambiguous and should be construed in favor of the employee. The Court of Appeals affirmed, concluding that the Board’s interpretation of “unexpected” was unreasonable and that the trial court properly had jurisdiction to hear the case.

The Tennessee Supreme Court disagreed, finding no ambiguity in the pension policy’s requirement that a qualifying traumatic event must be “unexpected.” Writing for a unanimous Court, Justice Mary L. Wagner held that “‘unexpected’ means happening without warning; not anticipated or regarded as probable within the normal course of duties.” The Court reasoned that while the incidents Mr. Long experienced were “horrific and traumatic,” they were not unexpected for a firefighter and thus did not meet the policy’s standard.

The Court also clarified that the liberal construction doctrine—which directs courts to interpret pension plans in favor of employees—does not apply when a policy is unambiguous. “Because the policy is unambiguous, the liberal construction doctrine cannot apply,” the opinion stated. The justices further held that the Board’s decision was supported by substantial and material evidence and was neither arbitrary nor capricious.

The Court concluded:

• There is little evidence that the events causing Mr. Long’s PTSD were ‘unexpected,’ and there is significant evidence that the events were expected.
• The Policy placed the burden of proof on Mr. Long to show that the events causing his PTSD were unexpected, and our review of the record yields little evidence that he met that burden.

Accordingly, the Supreme Court reversed the judgments of both the Court of Appeals and the trial court, reinstating the Board’s denial of benefits. The case was remanded to the Chancery Court for further proceedings consistent with the opinion. Here is a copy of the decision.