The Supreme Court of Tennessee’s Special Workers’ Compensation Appeals Panel recently affirmed a decision by a state trial court awarding an X-ray technician permanent and total disability benefits because of migraine headaches that the trial court had found were exacerbated by the technician’s exposure to chemical odors at her employer’s medical clinic. The case, Patton v. Paris Henry County Medical Clinic, was characterized by major differences between clinicians regarding causation. The defense argued that Patton, who is female, was more likely to be suffering from “hormonal fluctuations” associated with perimenopause that are causing the migraines – despite the fact that Patton had a partial hysterectomy prior to working at the clinic. However, ultimately, the trial court found the treating physician (Dr. Diamond), who specializes in headache medicine, to have more weight than the other experts who had never treated Patton, despite the fact that the AMA disability guidelines assign a maximum 5 percent rating for migraines. The Tennessee Supreme Court upheld the award.