The Massachusetts Workers’ Compensation Act (the Act) protects employees in that it allows them to seek compensation for workplace injuries. In exchange for that right, the Act precludes them from pursuing tort claims against their employers for work-related harm. As discussed in a recent Massachusetts case, however, it does not preclude all claims against employers. If you were hurt at work, it is important to understand your rights, and you should speak to a Massachusetts workers’ compensation attorney as soon as possible.
Facts of the Case
It is reported that the plaintiff initiated legal proceedings against his former employer and its parent company, the defendants, invoking the Massachusetts Whistleblower Protection Act (WPA) and alleging common law breach of contract. Initially, the court dismissed certain claims but allowed the breach of contract claim based on safety standards, reporting requirements, record-keeping, and quality assurance to proceed. Defendants subsequently sought a more definite statement, prompting the plaintiff to specify the collective bargaining agreement (CBA) of April 1, 2019, as the contractual basis for his breach of contract claims. The current matter revolves around the Defendants’ second Motion to Dismiss, seeking the dismissal of specific claims on preemption grounds.
Preclusion of Claims Under the Massachusetts Workers’ Compensation Act
The court engaged in a comprehensive analysis of the claims, first addressing the preemption issue regarding the breach of contract claims in Count III. Defendants contended that Section 301 of the Labor Management Relations Act (LMRA) preempted these claims, as they allegedly required interpretation of the CBA. The court invoked the “complete preemption” doctrine, emphasizing that claims falling within the ambit of LMRA § 301 could be deemed federal, thereby warranting removal. In this instance, the court concluded that Plaintiff’s breach of contract claims directly implicated the CBA, necessitating its interpretation, and thus fell within the scope of LMRA § 301 preemption. As a result, the court granted the Defendants’ motion to dismiss Count III, precluding state law claims based on the CBA.
Turning to the Workers’ Compensation Act cases cited by Defendants to support their preemption argument, the court distinguished them, highlighting the unique language in the Act subordinating statutory rights to collective bargaining agreements. Unlike the WCA cases, the the Act contains no such provision, allowing the court to draw a distinction between the two. Consequently, the court determined that Plaintiff’s WPA claim, centered on allegations of retaliation for safety concerns, did not require interpretation of the CBA, emphasizing the independence of WPA rights from collective bargaining agreements. Rejecting the preemption argument, the court denied Defendants’ motion to dismiss Count II and remanded it to state court, marking the sole remaining count exclusive to state law claims.
Meet with an Experienced Massachusetts Attorney
If you suffered injuries while working, you most likely can seek benefits under the Act, and you should talk to an attorney about your potential claims. James K. Meehan of the Law Office of the Law Offices of James K. Meehan is an experienced Massachusetts workers’ compensation lawyer with the skills and resources needed to help you seek the best outcome possible. To contact Mr. Meehan to arrange a meeting, you can use the online form or call him at 508-822-6600.