Employees who suffer workplace injuries often rely on statutory systems to obtain medical care and wage replacement. When an adverse employment action follows an injury report, disputes may arise over whether the employer acted lawfully or retaliated against the employee for exercising protected rights. A recent decision from a federal court addresses these concerns and clarifies how courts should evaluate causation and pretext at the summary judgment stage. If you have questions about retaliation or workers’ compensation-related employment actions, you should consult a knowledgeable Massachusetts workers’ compensation attorney to assess your available legal options.
History of the Case
Allegedly, the plaintiff worked for the defendant airline as a cross-trained agent responsible for customer service, operations, and ramp duties at an airport. During a work shift, the plaintiff sustained a head injury when an aircraft cabin door malfunctioned and struck him. A pilot prepared an internal incident report attributing the accident to maintenance failures, and the plaintiff informed a supervisor of the incident before completing his shift and seeking hospital treatment.
It is alleged that, despite the work-related nature of the injury, the defendant did not promptly provide the documentation necessary for the plaintiff to seek treatment through the Commonwealth workers’ compensation system. Instead, the plaintiff was told to rely on personal insurance, which delayed his formal report to the State Insurance Fund. Over time, the plaintiff experienced worsening symptoms, including neck pain and numbness, leading to diagnostic testing and eventual surgery.
Reportedly, once the plaintiff began receiving treatment through the State Insurance Fund, he became unable to perform his job duties and was placed on leave under the Family and Medical Leave Act. Medical professionals repeatedly extended his period of rest, setting a projected return-to-work date several months in the future. During this period, supervisors and human resources personnel communicated internally about the plaintiff’s employment status.
It is reported that, while the plaintiff remained on medical leave and was actively receiving workers’ compensation treatment, the defendant issued a termination letter. The letter stated that the plaintiff failed to keep the employer informed of his status and that multiple attempts to contact him had gone unanswered. The termination was made retroactively effective to a date during the plaintiff’s medical leave, despite the employer’s knowledge that he remained under active medical restrictions.
Retaliation in the Context of Workers’ Compensation Claims
On appeal, the court reviewed the district court’s grant of summary judgment de novo, viewing the record in the light most favorable to the employee. The sole issue before the court was whether summary judgment was appropriate on the employee’s retaliation claim.
The court explained that retaliation claims under the statute follow a burden-shifting framework similar to federal Title VII analysis. An employee must first establish a prima facie case by showing protected activity, an adverse employment action, and a causal connection between the two. Once established, the employer must articulate a legitimate, non-retaliatory reason for the termination, after which the burden shifts back to the employee to demonstrate pretext.
The district court concluded that the employee failed to establish causation because five months elapsed between the protected activity and the termination. The court rejected this approach, emphasizing that temporal proximity is only one factor in assessing causation and is not a mandatory requirement. The court clarified that an employee may rely on the totality of the circumstances, including inconsistent explanations and evidence of antagonism, to support an inference of retaliatory motive.
The court further determined that genuine disputes of material fact existed regarding pretext. The termination letter cited failure to communicate as the reason for discharge, while later litigation positions emphasized operational needs and staffing concerns. Evidence suggested that discussions about termination began earlier than the employer claimed and overlapped with the expiration of protected medical leave. These shifting and potentially contradictory explanations, the court held, could allow a reasonable jury to find that the stated reasons were not credible.
Because the district court improperly weighed evidence and resolved factual inferences at the summary judgment stage, the appellate court vacated the dismissal of the retaliation claim and remanded the case for further proceedings.
Speak with an Experienced Massachusetts Workers’ Compensation Attorney
Termination following a workplace injury or workers’ compensation claim raises serious legal questions that demand careful analysis. If you believe an employer has taken adverse action after you exercised your rights, you should talk to an attorney about your options. James K. Meehan of the Law Office of James K. Meehan is an experienced Massachusetts workers’ compensation attorney who represents clients throughout Massachusetts in workers’ compensation and related employment matters, including retaliation disputes, and he can help you protect your interests. You can contact Attorney Meehan at 508-822-6600 or submit an inquiry through the firm’s online contact form to set up a meeting.