Massachusetts workers’ compensation law generally provides the exclusive remedy for employees injured in the course of employment. However, certain tort claims may fall outside that statutory bar if they arise from intentional and malicious conduct rather than mere workplace injury or negligence. A recent decision from a Massachusetts Court clarifies when the exclusivity provision does and does not apply to claims for emotional distress allegedly caused by coworkers and supervisors. If you are suffering from mental or emotional injuries related to workplace treatment, a Massachusetts workers’ compensation attorney can help you evaluate your legal remedies.
Factual Background and Procedural History
It is reported that the plaintiff, a judicial staff attorney at the Massachusetts Appeals Court, brought a civil action against a coworker, a supervisor, and a court administrator, alleging intentional interference with advantageous relations. The plaintiff claimed the defendants orchestrated a campaign of harassment and malicious conduct that culminated in his termination. According to the complaint, the coworker expressed hostility toward the plaintiff’s professional background, discouraged staff from attending his writing seminar, and solicited criticism from judges. Following a promotion, she began issuing negative evaluations.
It is alleged that the supervisor initially praised the plaintiff’s work but later began criticizing his performance, extending his probation and permitting the coworker to oversee his work. Reports from other staff attorneys indicated the plaintiff was subjected to unique scrutiny and undue pressure. The supervisor did not intervene when informed of the coworker’s behavior.
It is further reported that the administrator issued a termination letter to the plaintiff citing performance deficiencies. The letter included several previously unraised or trivial allegations. The plaintiff requested access to his personnel file to prepare a response but was denied full documentation. He submitted a rebuttal letter but was terminated shortly thereafter. He alleged that this pattern of mistreatment contributed to anxiety, depression, and insomnia.
The trial court dismissed the claims against the supervisor and administrator but allowed the claim against the coworker to proceed. Both sides appealed, and the Supreme Judicial Court granted direct appellate review.
Workers’ Compensation and the Exclusivity Provision
The defendants argued that the plaintiff’s tort claim was barred by the exclusivity provision of the Massachusetts Workers’ Compensation Act, codified at G.L. c. 152, § 24. This provision limits an employee’s ability to pursue civil litigation for injuries arising out of and in the course of employment, channeling such claims through the workers’ compensation system. However, courts recognize exceptions where an employee alleges harm resulting from intentional acts of coworkers or supervisors undertaken with malice and outside the scope of legitimate employment interests.
It is reported that the defendants asserted this defense on appeal by referencing arguments made in their motion to dismiss. The court declined to address the exclusivity bar in detail, finding that the defendants failed to properly brief the issue under the Massachusetts Rules of Appellate Procedure. The court noted that a passing reference to the exclusivity provision without developed argument was insufficient to preserve the issue for appellate review.
Speak With a Massachusetts Workers’ Compensation Attorney
Claims for workplace-related emotional harm require a careful analysis of whether the workers’ compensation exclusivity bar applies. If you have suffered harm at work, you may be able to recover workers’ compensation benefits, and you should consult an attorney. Attorney James K. Meehan of the Law Office of James K. Meehan can evaluate your case and advise you of your rights. You can contact him at 508-822-6600 or reach out through our online form to schedule a confidential consultation.