Massachusetts Court Discusses Workers’ Compensation Claims for Traveling Employees

Workers’ compensation laws often intersect with personal injury claims, particularly in complex cases involving travel or injuries that occur outside a worker’s usual place of employment. In such cases, both the Workers’ Compensation Act (WCA) and applicable state law can determine whether the injured party may proceed with a claim. A recent case illustrates the significant impact of choice-of-law decisions in the workers’ compensation context and the importance of timely filing within the relevant statute of limitations. If you were hurt while traveling for work, you should talk to a Massachusetts workers’ compensation attorney about your rights.

Factual and Procedural Background

It is reported that the plaintiff, a Connecticut resident employed by a Massachusetts-based company, suffered an injury on a Delta Air Lines flight while traveling from Connecticut to Georgia for a work-related conference. Reportedly, the plaintiff’s employer, which had an office in Massachusetts, paid for the plaintiff’s travel, accommodations, and associated expenses as part of a continuing education program.

It is reported that while seated on the airplane, the plaintiff was struck by a beverage cart, which became unrestrained and collided with his knee. The incident allegedly led to significant pain, swelling, and, ultimately, a surgical procedure. The plaintiff received medical treatment in both Connecticut and Massachusetts before filing a claim in Massachusetts, asserting that he was injured in the course of employment and seeking compensation for negligence and breach of contract. The defendant removed the case to federal court based on diversity jurisdiction.

Workers’ Compensation Considerations for Traveling Employees

The court’s primary task was to determine which state’s law applied, as this would influence whether the plaintiff’s claim was timely. Massachusetts law provides a three-year statute of limitations for personal injury claims, while Connecticut imposes a shorter two-year limit. In the context of workers’ compensation, determining the applicable law also involves assessing where the injury occurred, the employee’s primary work location, and where medical treatment was received.

Although the plaintiff argued that Massachusetts had a more significant relationship to the employment relationship, the court disagreed. The court found that the injury took place in Connecticut airspace and that the plaintiff was a resident of Connecticut who received the majority of his medical care there. Additionally, the plaintiff had not filed a workers’ compensation claim in Massachusetts.

Further, even if he had, the financial implications of workers’ compensation and other Massachusetts laws did not create a substantial interest to overcome a more significant relationship to the claim. Finally, the flight originated in Connecticut. As such, even though the employer’s regional office was located in Massachusetts, the court concluded that Connecticut had the most direct and substantial relationship to the injury.

Speak with a Seasoned Massachusetts Workers’ Compensation Attorney Today

When a work-related injury occurs during travel or in another state, determining where and how to file for compensation can be complex. Statutory deadlines and jurisdictional rules play a crucial role in workers’ compensation claims, and failure to comply can bar recovery. If you were injured on the job or during work travel, you should talk to a lawyer about your rights. Attorney James K. Meehan of the Law Office of James K. Meehan is a seasoned Massachusetts workers’ compensation attorney with extensive experience handling workers’ compensation matters across Massachusetts, and if you hire him can evaluate your options and help you pursue the compensation you deserve. To schedule a consultation, call 508-822-6600 or reach out through the firm’s online form.