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Massachusetts Court Discusses Injuries in the Scope of Employment

The Massachusetts Workers’ Compensation Act (the Act) protects Massachusetts employees in that it allows them to recover benefits if they are injured while working. The Act is the sole remedy for such injuries, meaning employees hurt on the job cannot pursue personal injury claims for their losses. A key factor in whether a claim falls under the purview of the Act is whether the harm in question arose in the scope of employment, as discussed in a recent Massachusetts case. If you were hurt at work, it is advisable to talk to a Massachusetts Workers’ Compensation lawyer about your options as soon as possible.

Factual and Procedural Background

It is alleged that the plaintiff, an employee of the defendant company, filed a lawsuit against his employer and a co-employee, alleging negligence after being struck by a vehicle operated by his co-employee. The accident occurred after the plaintiff had completed his shift, clocked out, and was walking toward his car in the designated employee parking lot at a distribution center where the defendant company operated. The vehicle that struck the plaintiff was owned by the defendant company and driven by the co-employee as part of their work duties.

It is reported that as a result of the accident, the plaintiff sustained various injuries. The plaintiff filed a complaint asserting common-law negligence claims against both the employer and co-employee. The defendants filed a cross-motion for summary judgment, arguing that the exclusivity provisions of the workers’ compensation act barred the plaintiff’s claims because the injuries arose out of and in the course of employment. The trial court granted the motions, and the plaintiff appealed.

Injuries in the Scope of Employment

On appeal, the court considered whether the plaintiff’s injuries occurred within the scope of employment and were, therefore, subject to the exclusivity provisions of the workers’ compensation act. The court explained that the Act provides the exclusive remedy for employees who sustain personal injuries arising out of and in the course of employment, barring them from pursuing common-law negligence claims against their employers and co-employees.

The court analyzed whether the plaintiff’s injuries were sustained while he was still engaged in employment activities or exposed to employment-related risks. It determined that the plaintiff was injured while departing work on a designated passage used by employees and controlled or accessible by the employer, which fell within the purview of employment-related activities covered by the workers’ compensation scheme.

The court further noted that injuries occurring in employer-controlled or employer-designated areas, such as parking lots, even when employees are leaving work, are considered to arise within the course of employment.

This determination was based on the broader principle that workers’ compensation applies if the employment exposes the employee to the specific risks that caused the injury, regardless of whether the precise location was under the employer’s control.

The court rejected the plaintiff’s argument that his injuries did not arise out of employment because they occurred in an area not directly controlled by the employer. Instead, it emphasized that the critical factor was whether the employment exposed the plaintiff to the risk of injury.

As the court concluded that the plaintiff’s injuries arose from an employment-related risk and were incidental to his work, the court affirmed the judgment of the trial court, holding that the plaintiff’s claims were barred by the Act’s exclusivity provisions.

Meet with a Trusted Massachusetts Workers’ Compensation Lawyer

If you suffered injuries at work, it is critical to understand your rights and what benefits you may be owed, and you should meet with an attorney. Attorney James K. Meehan is a trusted Massachusetts workers’ compensation lawyer who can evaluate your harm and aid you in pursuing any benefits available. You can reach Attorney Meehan at 508-822-6600 or via our online contact form to set up a private meeting.

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