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Massachusetts Court Discusses Discrimination in the Context of Workers’ Compensation Claims

Workers’ compensation claims can have lasting consequences beyond the payment of benefits, particularly when an employee returns to work after a serious injury and later faces discipline or termination. Employers may assert safety or performance reasons for an adverse action, while employees may question whether concerns about future workers’ compensation exposure influenced the decision. A recent ruling from a Massachusetts court examines this tension and clarifies how workers’ compensation considerations may intersect with disability discrimination claims under state law. If you believe your work-related injury played a role in a termination decision, you should consider speaking with a Massachusetts workers’ compensation attorney to understand your rights.

Case Setting

Allegedly, the plaintiff was employed by the defendant as a commercial truck driver and suffered a serious back injury while performing job duties. The injury required surgery and resulted in an extended period away from work, during which the plaintiff received workers’ compensation benefits paid by the defendant.

It is alleged that the plaintiff later returned to full-time work and resumed operating heavy equipment. Approximately two months after returning, the plaintiff was involved in a workplace incident while unloading a truck at a landfill when the vehicle tipped over. The plaintiff was not injured in the incident, but the equipment sustained damage.

Reportedly, the defendant investigated the incident and concluded that it was preventable and caused by operator error. Based on that determination, management terminated the plaintiff’s employment, citing violations of company safety policies and concerns about judgment while operating dangerous machinery.

It is reported that the plaintiff filed a civil action asserting that the termination was motivated by the defendant’s desire to avoid potential future workers’ compensation liability related to the earlier back injury. A jury returned a verdict in favor of the plaintiff and awarded damages, including punitive damages. The defendant filed post-trial motions challenging the verdict, which were denied, and the defendant appealed. The Supreme Judicial Court granted direct appellate review.

Disability Discrimination in the Context of Workers’ Compensation Claims

The court reviewed the case to clarify the legal standards governing disability discrimination claims in which workers’ compensation history is central to the dispute. It explained that a plaintiff need not prove termination occurred solely because of a disability to establish a prima facie case. Instead, the plaintiff must show a qualifying impairment, the ability to perform essential job functions, an adverse employment action, and circumstances supporting an inference of discrimination.

The court focused on how workers’ compensation considerations should be evaluated by a jury. It emphasized that an employer’s statutory obligation to pay workers’ compensation benefits does not end with termination and that jurors must understand this legal reality when assessing motive. Because the plaintiff argued that the defendant terminated employment to avoid future workers’ compensation exposure, the court concluded that the jury should have been instructed that termination would not eliminate that obligation.

The court also determined that the trial court improperly admitted evidence concerning outdated employment application materials and generalized efforts to reduce workers’ compensation costs. It explained that such evidence was not sufficiently probative of discriminatory intent and risked misleading the jury into equating cost awareness with unlawful motive.

Although the court concluded that the plaintiff presented enough evidence to allow a jury to consider whether workers’ compensation concerns influenced the termination decision, it held that the instructional and evidentiary errors required a new trial. The court further ruled that the evidence did not support punitive damages, explaining that speculative concerns about future workers’ compensation liability did not rise to the level of outrageous conduct or reckless indifference. The case was remanded for a new trial without punitive damages.

Talk to an Assertive Massachusetts Workers’ Compensation Attorney

If you believe your work-related injury or benefits influenced an employment decision, you should talk to an attorney. James K. Meehan of the Law Office of James K. Meehan is an assertive Massachusetts workers’ compensation attorney who assists clients throughout Massachusetts with workers’ compensation claims, and if he represents you, he will diligently pursue the best legal outcome possible in your case. You can contact him at 508-822-6600 or submit a request through the firm’s online contact form to arrange a consultation and discuss your legal options.

 

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