Massachusetts Injury Lawyers Blog
Airline employees face certain risks in the course of their duties, particularly during turbulent flights, which can turn routine tasks into hazardous situations. When worker injuries occur during flights, whether the injured employee is eligible for workers’ compensation benefits often hinges on the credibility of the employee’s testimony and the medical evidence presented. A recent decision from a Massachusetts court highlights how administrative judges evaluate causation in such cases and clarifies the deference afforded to credibility findings and the weighing of medical testimony. If you were injured on the job, speaking with a Massachusetts workers’ compensation attorney can help ensure that your rights are protected throughout the claims process.
History of the Case
Allegedly, the employee worked as a flight attendant for the employer and claimed that he injured his hand during a turbulent flight between Florida and Massachusetts when a metal food cart tilted backwards and crushed his right hand. The employee was treated several days later and was diagnosed with a fracture of the fourth metacarpal bone. The matter proceeded to a hearing before an administrative judge, who considered testimony from the employee, deposition testimony from medical providers, and documentary evidence. The judge found the employee credible and concluded that the fracture was caused by the workplace incident involving the food cart.
It is alleged that the insurer appealed, arguing that the employee did not establish causation because the medical testimony did not explicitly confirm that the cart incident caused the fracture. The insurer pointed to evidence that the employee worked regular shifts after the incident and that he reportedly told a nurse practitioner that he hurt his hand playing basketball. The insurer relied heavily on the testimony of the treating physician, who stated that the employee’s injury could have involved both a workplace event and a sports-related event. The administrative judge, however, determined that the employee never reported that he injured his hand playing basketball and accepted the employee’s explanation that he had merely attempted to test his hand strength by trying to palm a basketball after the injury.
Reportedly, the judge awarded the employee a closed period of workers’ compensation benefits for the physical injuries. The Department of Industrial Accidents reviewing board summarily affirmed the administrative judge’s decision. The insurer then appealed, challenging the finding of causation and the reliance on the employee’s testimony.
Demonstrating an Injury is Work-Related
On appeal, the court reviewed the case under the standards set forth in G. L. c. 152, § 12 (2), and G. L. c. 30A, § 14. The court explained that it may reverse or modify the board’s decision only if it is legally erroneous, arbitrary, capricious, or unsupported by substantial evidence. When the board summarily affirms the administrative judge, the reviewing court evaluates the administrative judge’s findings and reasoning directly.
In workers’ compensation cases, the employee bears the burden of proving by a preponderance of the evidence that the claimed injury arose out of employment. While medical testimony must establish causation in cases beyond lay knowledge, the court emphasized that administrative judges retain the authority to assess credibility, weigh conflicting testimony, and determine which parts of expert opinions to adopt. The court noted that the treating physician testified that the workplace incident likely caused the initial fracture, which might later have been aggravated by a sports-related activity. The administrative judge permissibly adopted this portion of the testimony while rejecting any implication that the injury originated outside of work.
The court stressed that credibility determinations are the exclusive province of the administrative judge, who may accept or discount portions of medical opinions, provided that the judge’s findings rest on evidence in the record. Here, the administrative judge found the employee credible, accepted his account of the incident, and determined that the injury occurred when the food cart struck his hand during the course of his employment. This factual predicate provided the foundation for adopting the medical opinion that the fracture occurred at work. Because the administrative judge’s findings were supported by substantial evidence, the court affirmed the award of benefits.
Talk to a Knowledgeable Massachusetts Workers’ Compensation Attorney
If a workplace incident has left you coping with medical issues or time away from your job, it is important to understand your rights, and you should talk to an attorney. James K. Meehan of the Law Office of James K. Meehan is a knowledgeable Massachusetts workers’ compensation lawyer with extensive experience guiding injured workers through the claims process and advocating for the benefits they deserve. To speak with Mr. Meehan, call 508-822-6600 or submit a request through the firm’s online contact form to arrange a consultation.