In Massachusetts, people injured in the workplace are generally precluded from filing negligence actions against their employers pursuant to the Workers’ Compensation Act. They may be able to seek damages from other parties who caused or contributed to their harm, though, as long as they have not otherwise waived the right to recover damages. Sometimes, however, it is not clear whether such a waiver occurred. In a recent opinion, a Massachusetts court analyzed whether a release issued in a workers’ compensation claim barred a plaintiff from pursuing damages in a negligence action, in a matter in which the plaintiff argued that collateral estoppel did not apply. If you sustained injuries while working, you might be able to recover damages, and you should meet with an experienced Massachusetts personal injury attorney about your potential claims.
The Defendant’s Claims
It is reported that the plaintiff was involved in a motor vehicle collision with a driver insured by the defendant. The plaintiff, who was working at the time of the collision, suffered substantial injuries. As such, he received workers’ compensation benefits from his employer’s insurer, who secured a lien against any compensation recovered from those at fault. Two years later, the plaintiff entered into a settlement agreement with the defendant, which stated that the defendant would pay the plaintiff $25,000 to resolve his claims against the insured driver, half of which would satisfy the workers’ compensation insurer’s lien and the other half of which would go to the plaintiff.
Allegedly, the release stated the plaintiff waived any and all claims against the defendant or the insured driver. The plaintiff then filed a negligence lawsuit against the insured driver, arguing that the agreement did not bar his action. The defendant moved for summary judgment, which the court granted, and the plaintiff appealed.
Collateral Estoppel Under Massachusetts Law
On appeal, the plaintiff argued that collateral estoppel did not apply because the issues in the matters were not identical. The court was not persuaded by this argument, noting that the plaintiff failed to cite any cases that supported his opinion, thereby failing to rise to the level of an appellate argument. The court further explained that collateral estoppel, also referred to as issue preclusion, could be applied defensively when there was a final ruling on the merits in the prior matter, the party against whom preclusion is asserted was either a party to the earlier case or in privity with a party, and the issue in the prior matter is identical to the issue in the current matter. In the subject case, the court found that all four elements were met. Thus, it affirmed the trial court ruling.
Meet with an Experienced Massachusetts Personal Injury Attorney
Workplace injuries are often caused by the negligence of third parties, and many people hurt at work can seek compensation from entities other than their employers. James K. Meehan of the Law Office of James K. Meehan is an experienced personal injury lawyer, and if you suffered harm while working, he can assess the circumstances surrounding your injuries and help you to pursue the full amount of damages recoverable under the law. You can reach Mr. Meehan through the form online or by calling him at 508-822-6600 to schedule a conference.