Massachusetts Injury Lawyers Blog
Under the Massachusetts Workers’ Compensation Act (the Act), employers generally must give employees who sustain work-related harm workers’ compensation benefits. Employers must fulfill this duty regardless of whether a third party causes the harm in question, and the employer may not have recourse for pursuing claims against the third party for damages; as discussed in a recent Massachusetts case. If you were wounded in a work accident, it is advisable to consult a Massachusetts workers’ compensation lawyer to discuss your possible claims.
Facts and Procedure of the Case
It is reported that the plaintiff employed an individual who sustained injuries in an industrial accident. Specifically, the employee suffered injuries when a dumpster owned by the defendant excavation company rolled off of a truck. The employee, who was at work during the accident, filed a workers’ compensation claim, which was covered by the employer’s insurer.
Allegedly the employer subsequently sued the excavation company, alleging that the excavation company’s negligence caused an increase in its workers’ compensation insurance costs. Specifically, the employer claimed it suffered economic losses in the form of a dividend loss from its insurance premium due to the accident. The excavation company moved for summary judgment, arguing it owed no duty to the employer and that the Workers’ Compensation Act foreclosed the employer’s claim. The trial court granted summary judgment in favor of the excavation company, ruling that no duty was owed to the employer. The employer appealed.
Third-Party Liability in Workers’ Compensation Claims
On appeal, the court affirmed the trial court ruling. The court explained that Massachusetts, like many jurisdictions, adheres to the traditional rule that purely economic losses are not recoverable in tort actions unless there is personal injury or property damage. Since the employer sought to recover economic damages without personal injury or property damage, its claim was barred by the economic loss doctrine.
The court emphasized that the employer’s loss stemmed from contract terms negotiated with its insurer and did not arise from personal injuries sustained by the plaintiff. Therefore, the employer could not maintain a negligence claim against the excavation company. Additionally, the court noted that the employer’s attempt to recover purely economic losses was inconsistent with modern legal principles and societal norms.
While acknowledging the approach taken by other jurisdictions that found damages too remote, the court primarily relied on Massachusetts law concerning the economic loss doctrine when making its determination. Specifically, it referenced a prior case where it was held that an employer could not recover damages for an employee’s diminished working ability, considering them too remote and indirect. Similarly, the damages sought by the employer were deemed too remote for recovery, affirming the judgment in favor of the excavation company.
Talk to a Dedicated Massachusetts Workers’ Compensation Attorney
Massachusetts employers have a duty to provide employees injured on the job with workers’ compensation benefits, regardless of whether another party caused the employee’s harm. If you sustained injuries at work, it is smart to talk to an attorney about what benefits you may be able to recover. Attorney James K. Meehan is a dedicated Massachusetts workers’ compensation lawyer with ample experience helping injured employees protect their rights. To reach Attorney Meehan, you can use our form online or call him at 508-822-6600 to arrange a confidential conference.