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Massachusetts Court Rules the Workers’ Compensation Act Bars Emotional Distress Claims

Pursuant to the Massachusetts Workers’ Compensation (the Act), people that suffer harm at work are generally eligible to recover workers’ compensation benefits. In exchange for the protections offered by the Act, though, they waive the right to pursue personal injury for damages from their employer. Notably, the Act precludes employees not only from filing claims seeking compensation for physical harm but also bars claims for emotional harm as well, as explained in a recent Massachusetts ruling. If you suffered physical or mental harm in the workplace, you might be owed benefits, and it is wise to confer with a Massachusetts workers’ compensation attorney regarding your rights as soon as possible.

The Facts of the Case

It is alleged that the plaintiff worked as a scientist for the defendant pharmaceutical company from October 2007 until November 2015. After the plaintiff made a presentation to his superiors, he faced harsh criticism. He subsequently developed mental health issues, of which he advised his employer. He was ultimately terminated. He then filed a lawsuit against the defendant, asserting that he was terminated due to his mental health issues, in violation of the ADA, and asserting claims for intentional infliction of emotional distress. The defendant moved for summary judgment.

The Massachusetts Workers’ Compensation Act Exclusivity Provisions

The court granted the defendant’s motion and dismissed the plaintiff’s claims. As to the plaintiff’s claims of intentional infliction of emotional distress, the court found that they were barred by the exclusivity provisions of the Act. Specifically, the court explained that pursuant to Massachusetts law, the Act precludes common law actions where the plaintiff is proven to be an employee of the defendant, his harm is deemed a personal injury as defined by the Act, and it is demonstrated that the harm arose out of and during the court of employment.

The court elaborated that where mental harm is a core element of an employee’s common law claim, it is an indispensable ingredient, and the claim is barred by the Act. The Act does not bar an employee from pursuing common law claims against their employer if the physical or mental harm alleged is incidental to the plaintiff’s claim.

In the subject case, the court found that mental harm was clearly an essential element of the plaintiff’s intentional infliction of emotional distress claim against the defendant. Thus, the Act precluded his claim.

Speak with a Knowledgeable Massachusetts Attorney

Employees who sustain injuries in the workplace can often recover workers’ compensation benefits, but in most instances, they are barred from recovering civil damages for their harm from their employer. If you were hurt while working, it is in your best interest to speak to an attorney about what benefits you may be owed. James K. Meehan of the Law Office of James K. Meehan is a knowledgeable Massachusetts workers’ compensation attorney who can assist you in seeking the best legal outcome possible under the facts of your case. You can reach Mr. Meehan by calling 508-822-6600 or via the form online to set up a conference.

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