The Massachusetts Workers’ Compensation Act (the Act) provides employees throughout the Commonwealth with the right to pursue benefits for illnesses or injuries that arise in the scope of employment. In exchange for that right, though, the Act bars people from pursuing tort claims from their employers, as discussed in a recent Massachusetts ruling. If you were injured in the workplace, you may be able to recover benefits, and you should talk to a Massachusetts workers’ compensation lawyer about your options.
Factual History and Procedural Setting
It is reported that the plaintiff injured his shoulder while picking up windows at the defendant’s request in February 2001. The incident occurred in an icy parking lot, where the plaintiff slipped and fractured his shoulder. At the time, there was no formal documentation regarding whether the plaintiff was an employee or an independent contractor. After the injury, the plaintiff filed a workers’ compensation claim, but the defendant’s insurer rejected it, claiming the plaintiff was an independent contractor. The plaintiff also initiated a personal injury lawsuit, first against the owner of the lumber yard and later adding the defendant, alleging negligence in directing him to work under dangerous conditions.
It is alleged that while pursuing both the workers’ compensation claim and the tort lawsuit, the plaintiff eventually settled with the defendant for a lump sum of $8,500 under the Act. The settlement agreement noted the dispute over the plaintiff’s employment status and allowed the plaintiff to continue his tort action. After the workers’ compensation settlement, the defendant failed to respond to the tort action, resulting in a default judgment in favor of the plaintiff. The plaintiff also settled with the lumber yard for $42,500. The defendant sought to vacate the default judgment, claiming that the Act’s exclusivity provision barred the plaintiff’s tort claim. The granted motion to vacate the default judgment and summary judgment in favor of the defendant based on the exclusivity provision. The plaintiff appealed.
Exclusivity Provision of the Act
On appeal, the court examined the scope of the Act’s exclusivity provision, which bars employees from pursuing common law claims against their employers after accepting workers’ compensation benefits. The court found that once the plaintiff accepted the lump sum settlement under the Act, he released the defendant from any common law claims arising from the same injury. The court emphasized that employee status was a condition of receiving the lump sum payment, meaning that the plaintiff could not claim to be an independent contractor in the tort action while simultaneously accepting workers’ compensation benefits as an employee.
The court also addressed the plaintiff’s argument that the settlement agreement reserved his right to pursue the tort claim. However, it concluded that the exclusivity provision could not be waived or modified by private agreement, as it was a central element of the statutory framework. Furthermore, the court determined that allowing both the workers’ compensation settlement and the tort judgment would undermine the legislative intent of the Act, which seeks to provide an efficient resolution of worker injury claims. As such, the court thus affirmed the lower court’s rulings in favor of the defendant.
Speak with an Experienced Massachusetts Workers’ Compensation Lawyer
If you were hurt at work, it is in your best interest to talk to an attorney about whether you can recover workers’ compensation benefits. Attorney James K. Meehan is an experienced Massachusetts workers’ compensation attorney with the knowledge and resources needed to help you seek a favorable result, and if you hire him, he will fight tirelessly on your behalf. You can contact Attorney Meehan at 508-822-6600 or through our online form to set up a confidential meeting.