In Massachusetts and in most other states, the workers’ compensation law dictates that employees who sustain work-related injuries can pursue workers’ compensation benefits from their employers. In exchange for that right, though, they are barred from pursuing tort claims for any harm that occurs within the scope of their employment. Recently, a Massachusetts court discussed what constitutes “in the scope of employment” in a case in which it ultimately found that the law precluded the plaintiff’s tort claims. If you were injured while working, you might be eligible to recover benefits, and you should meet with a Massachusetts Workers’ Compensation attorney.
Case Setting
It is alleged that both the plaintiff and defendant were California residents and employees of a technology company; they were on a multi-city business trip with another co-worker. Their employer arranged and paid for all travel, including airline, hotel, and rental car reservations. They arrived at the airport in Boston and decided to do some sightseeing before heading to their hotel in Burlington, Massachusetts. While the defendant was driving and the plaintiff was in the rear passenger seat, they got lost and ended up in Somerville, Massachusetts. The defendant ran a red light and collided with another vehicle, resulting in injuries to both the plaintiff and the occupants of the other vehicle.
It is reported that the occupants of the other vehicle sued the defendant and the employer, and the case settled with the employer’s insurer paying the settlement and workers’ compensation benefits to the plaintiff. Subsequently, the plaintiff filed the present action against the defendant, who moved for summary judgment, claiming immunity under California’s Workers’ Compensation Act. The plaintiff argued they were not within the scope of their employment during the accident since they were sightseeing on a day off. The court initially denied the summary judgment motion without prejudice, inviting the defendant to renew the motion if evidence showed the plaintiff had applied for workers’ compensation benefits and if there was legal clarification on “within the scope of employment.” The defendant then renewed his motion.
Scope of Employment in the Context of Workers’ Compensation Claims
The court reviewed the case to determine whether the plaintiff and defendant were acting within the scope of their employment during the accident, which would make workers’ compensation the plaintiff’s exclusive remedy and bar the present action.
The court noted that California law applies, and under California Labor Code, employers are liable for injuries sustained by employees arising out of and in the course of employment, with workers’ compensation as the exclusive remedy.
It was established that the plaintiff had applied for and received workers’ compensation benefits, characterizing the accident as work-related. The court evaluated whether the defendant’s actions were within the scope of employment, considering the foreseeability test and the two-prong test used by California courts.
The court concluded that sightseeing during a business trip was reasonably foreseeable by the employer and incidental to the employee’s duties. The court also noted that activities necessary for the employee’s comfort and convenience, even if personal, do not take them outside the scope of employment.
Therefore, the court ruled that the defendant’s actions were within the scope of employment, granting the defendant’s motion for summary judgment and barring the plaintiff’s action under the exclusive remedy provision of the workers’ compensation law.
Speak with a Qualified Massachusetts Workers’ Compensation Attorney
Workers injured on the job have the right to seek workers’ compensation benefits, though employers often contest the work-related nature of an injury to escape liability. If you suffered an injury at work, it is prudent to speak with an attorney about your options. Attorney James K. Meehan is a qualified Massachusetts workers’ compensation lawyer who can inform you of your rights and help you pursue the best possible legal result in your case. To set up a confidential consultation, you can reach Attorney Meehan at 508-822-6600 or through our user-friendly online contact form.