Massachusetts Court Discusses Dismissal of Injured Employee’s Civil Claims

Massachusetts, like many states, enacted a Workers’ Compensation Act (the Act) that grants employees injured at work the right to recover benefits. The Act bars employees from pursuing civil claims against their employers, however. While employers will often assert that the exclusivity provision of the Act bars civil claims, it may not constitute grounds for dismissal of a case prior to the exchange of discovery, as demonstrated in a recent opinion issued by a Massachusetts court. If you were hurt at work, you could be owed benefits, and it is smart to meet with a knowledgeable Massachusetts workers’ compensation lawyer to determine your rights.

The Plaintiff’s Harm

It is alleged that the plaintiff was employed by a tool company as a machinist. The tool company was a wholly-owned subsidiary of the defendant. The plaintiff injured her hand on a machine while she was working and subsequently filed a civil lawsuit against the defendant. The plaintiff’s complaint asserted that the defendant should be held liable for negligence and negligent supervision.

It is reported that the plaintiff alleged the defendant breached its duty to provide a safe workplace, reasonably supervise the worksite, and ensure employees were properly trained. The defendant moved for judgment on the pleadings, arguing it was the statutory employer of the plaintiff and, therefore, her claims were barred by the exclusivity provision of the Act. The court denied the motion, and the defendant appealed.

Determining Whether Exclusivity Provision of the Act Applies

The trial court ruling was affirmed on appeal. The court was not persuaded by the defendant’s argument that the court erred in failing to consider extrinsic evidence that was attached to the complaint, noting that a court weighing a motion for judgment on the pleadings could consider matters of public record, court orders, and exhibits attached to the complaint without converting the motion to one for summary judgment, the evidence offered by the defendant did not fall into any of those categories.

Further, in cases such as the subject matter where the documents outside of the pleadings are not referred to in the complaint, a court cannot convert the motion into one for summary judgment without providing notice to the other parties in the action. The appellate court found that the trial court properly declined to convert the motion and consider the documents offered by the defendant in this early stage of proceedings where discovery had not yet been conducted. Thus, it affirmed the trial court ruling.

Speak to a Trusted Massachusetts Workers’ Compensation Attorney

Workplace injuries can cause critical harm and a significant loss of income, but fortunately, the law affords injured employees the right to recover workers’ compensation benefits. If you were hurt at work, it is in your best interest to speak to an attorney regarding what benefits you may be owed. James K. Meehan of the Law Office of James K. Meehan is a trusted Massachusetts workers’ compensation lawyer who is proficient at helping injured workers protect their interests, and if you hire him, he will work tirelessly on your behalf.  You can reach Mr. Meehan by calling him at 508-822-6600 or using the online form to schedule a conference.