Court Explains the Exclusivity Provision of the Massachusetts Workers’ Compensation Act

The Massachusetts Workers’ Compensation Act (the Act) grants employees who suffer harm in the workplace the right to seek workers’ compensation benefits. The exclusivity provision of the Act generally precludes employees from pursuing personal injury claims against their employer, however. In other words, they are limited to recovering benefits under the Act. Recently, a Massachusetts court discussed whether claims for emotional distress are barred by the exclusivity provision in a case in which the plaintiff sought damages from her coworkers. If you were harmed by workplace conditions, it is smart to confer with a seasoned Massachusetts workers’ compensation lawyer to discuss what claims you may be owed.

The Plaintiff’s Claims

It is alleged that the plaintiff filed a lawsuit against her former coworkers and former employer. In the complaint, the plaintiff asserted that she suffered personal injuries as a result of the toxic work environment created by the defendants. The defendants filed a motion to dismiss, arguing that the exclusivity provision of the Act prohibited the plaintiff’s claims. The court agreed and dismissed the plaintiff’s complaint. The plaintiff appealed.

The Exclusivity Provision of the Massachusetts Workers’ Compensation Act

On appeal, the plaintiff argued that the trial court erred in dismissing her intentional infliction of emotional distress claim because she sufficiently set forth an actionable claim, as much of her allegations focused on the actions of the individually named defendants rather than the actions of the employer. The appellate court stated that Massachusetts law required it to review, de novo, whether the motion to dismiss was properly granted.

In doing so, the appellate court took the allegations of the complaint as true and drew all reasonable inferences in the plaintiff’s favor to determine whether the facts, as alleged, plausibly suggested she was entitled to relief. The appellate court noted that the allegations in the complaint indicated that the conduct of the defendants, which allegedly caused the plaintiff’s harm, occurred directly within the scope of the individual defendant’s employment and in furtherance of the defendant employer’s interests.

The appellate court affirmed, therefore, that the plaintiff’s intentional infliction of emotional distress was barred by the exclusivity provision of the Act. In support of its ruling, the appellate court explained that employees working within the scope of their employment in an effort to further the interests of their employer are protected from personal injury claims pursued by their coworkers by the exclusivity provision of the Act.

The appellate court also noted that the Massachusetts courts had previously ruled that the Act barred intentional tort claims for harm that occurred in the course of employment. As such, the appellate court affirmed the trial court ruling.

Speak to an Experienced Massachusetts Workers’ Compensation Lawyer

People who suffer physical or emotional harm at work are often entitled to workers’ compensation benefits and should contact an attorney. James K. Meehan of the Law Office of James K. Meehan is an experienced workers’ compensation attorney, and if you were hurt at work, he could help you to seek the maximum benefits available under the law. You can contact him via the online form or by calling 508-822-6600 to set up a conference.