The Massachusetts Workers’ Compensation Act (the Act) provides employees with the right to seek benefits for workplace injuries that impact their ability to work, including partial incapacity benefits for injuries that diminish a worker’s earning capacity. To qualify for these benefits, however, an injured worker must show that their work-related injury has impacted their ability to perform job-related tasks. A recent Massachusetts case highlights the importance of accurate job duty assessments and the need for substantial evidence when determining an employee’s eligibility for partial incapacity benefits. If you were hurt at work, it is wise to talk to a Massachusetts Workers’ Compensation attorney regarding what steps you can take to protect your interests.
Factual and Procedural Background
It is reported that the petitioner, an employee, was injured in an explosion during his employment, resulting in abdominal and right eye injuries from shrapnel. He initially received benefits from his employer’s insurer for the injury and later filed for partial incapacity benefits under Massachusetts law. The administrative judge presiding over his case assessed the petitioner’s job duties, concluding that they were primarily office-based with occasional field duties, despite evidence from the petitioner and a vocational expert indicating that his role involved mostly fieldwork. After his initial employment, the petitioner continued similar work for other contractors, performing both field and office roles. Eventually, he obtained a solely office-based position, which he held briefly before being laid off.
Allegedly, he ultimately ceased working, and an impartial medical examiner concluded he should avoid industrial environments that posed risks to his remaining functional eye. The Department of Industrial Accidents denied the petitioner’s claim for partial incapacity benefits, asserting that his work capacity had not decreased due to his injury. The petitioner appealed, arguing that the administrative judge’s conclusions about his job duties were inaccurate and that his work capacity was impaired. The reviewing board upheld the judge’s decision, prompting the petitioner’s appeal.
Compensation for Reduced Work Capacity
On appeal, the court reviewed whether the administrative judge’s findings on the petitioner’s job duties and work capacity were based on substantial evidence, as required by Massachusetts law. The court found that the administrative judge’s interpretation of the petitioner’s job as primarily office-based was unsupported, given the overwhelming evidence that fieldwork comprised a significant portion of his duties. The court concluded that this misinterpretation influenced the judge’s decision regarding the petitioner’s earning capacity, rendering it arbitrary.
In its analysis, the court referenced established case law indicating that compensation is warranted when a workplace injury reduces a worker’s earning capacity. The court emphasized that the administrative judge’s decision ignored substantial evidence showing the reinjury risk posed by the petitioner’s field duties, particularly given his impaired vision. Under Massachusetts law, workers who are advised by medical professionals to avoid prior duties due to health risks may be eligible for partial incapacity benefits. Finding that the judge’s decision lacked adequate evidentiary support, the court vacated the judgment and remanded the case for further proceedings in line with these legal standards.
Consult a Trusted Massachusetts Workers’ Compensation Lawyer
If you were hurt while working, you may be entitled to workers’ compensation benefits, and it is important to consult with a knowledgeable attorney promptly. Attorney James K. Meehan is a trusted Massachusetts workers’ compensation attorney who can guide you through your legal options and help you seek a just outcome. To arrange a confidential meeting, you can reach Attorney Meehan at 508-822-6600 or through our online form.