Massachusetts Court Discusses Administrative Remedies in Workers’ Compensation Claims

The Massachusetts Workers’ Compensation Act sets forth numerous rules regarding workers’ compensation claims and benefits for employees, employers, and insurance companies. If a party fails to comply with such rules and subsequently seeks intervention from the courts, their claim may be denied, as demonstrated in a recent Massachusetts case. If you need assistance pursuing workers’ compensation benefits following an injury, it is smart to talk to a Massachusetts workers’ compensation lawyer as soon as possible.

Procedural and Factual Background

It is reported that the plaintiff was injured while working for the employer’s landscaping company. The employee filed for workers’ compensation benefits from the insurer, which contested his claim. An administrative judge ordered temporary benefits and medical coverage pending a formal hearing, a decision both parties appealed. While the case awaited the hearing, the insurer initiated a Superior Court action to declare two insurance policies void, alleging misrepresentations. the employer did not oppose, resulting in a default judgment against him.

Allegedly, the employee responded but did not contest the insurer’s motion, leading to a judgment declaring the policies void. Using this judgment, the insurer requested dismissal from the DIA case but was denied. A second Superior Court action sought to enjoin DIA proceedings. In response, the employee requested relief from the declaratory judgment, claiming the court had no jurisdiction.

It is stated that the judge in the second Superior Court action temporarily halted DIA proceedings. The Fund intervened in the first Superior Court action, supporting the employee’s motion. At the hearing, the employee and the Fund argued that the insurer hadn’t exhausted administrative remedies, depriving the court of jurisdiction. The court agreed, vacated prior orders, and dismissed the insurer’s complaint without prejudice. The insurer appealed.

Administrative Remedies in Workers’ Compensation Cases

The issue on appeal was whether the insurer was required to exhaust its administrative remedies before going to court. The court conducted a de novo review and concluded that the exhaustion rule was applicable in the absence of a statutory directive to the contrary. Massachusetts General Laws did not contain such a directive, and it was uncontested that the insurer had not exhausted its administrative remedies before filing in Superior Court.

The court emphasized the importance of the exhaustion doctrine in workers’ compensation cases, allowing agencies to apply their expertise and avoiding piecemeal judicial review. The DIA had full authority to decide insurance coverage disputes, including those related to rescission, and seeking declaratory relief did not exempt the insurer from exhausting administrative remedies.

As such, the court affirmed the judgment, dismissing the case for lack of jurisdiction, finding no abuse of discretion in allowing the Fund to intervene, and appropriately relieving the insurer from judgment due to the court’s lack of jurisdiction.

Consult a Capable Massachusetts Attorney

If you were hurt while working, you may be owed benefits, and it is in your best interest to speak to an attorney. James K. Meehan of the Law Office of James K. Meehan is a capable Massachusetts workers’ compensation lawyer who can evaluate your potential claims and aid you in pursuing any benefits recoverable. You can contact Mr. Meehan to arrange a meeting through the online contact form by calling him at 508-822-6600.