Massachusetts Injury Lawyers Blog
In Massachusetts, public employees seeking accidental disability retirement benefits must prove that their disability is the natural and proximate result of a workplace injury. This standard requires clear, persuasive medical evidence, typically from a regional medical panel. A recent decision by a Massachusetts highlights the challenges claimants face when panel findings are equivocal. If your claim for disability retirement has been denied due to medical uncertainty or panel findings, a Massachusetts workers’ compensation attorney can help protect your rights.
Factual Background and Procedural History
It is reported that the claimant, a public employee serving as a truck driver for a Massachusetts Department of Public Works, applied for accidental disability retirement benefits following a low back injury he sustained while lifting heavy equipment. The claimant reported that the injury occurred when he attempted to lift a plow blade weighing over 100 pounds. Following the incident, he sought medical treatment and eventually ceased working due to ongoing pain and functional limitations.
It is alleged that the claimant underwent an evaluation by a regional medical panel pursuant to G.L. c. 32, § 6(3)(a). The panel unanimously concluded that the claimant was permanently disabled from performing the essential duties of his position. However, the panel also stated that it could not determine with certainty whether the disability was caused primarily by the work-related injury. The panel’s report used qualified language and stated that there was “no clear-cut evidence” linking the injury to the present disability.
It is further reported that despite the panel’s ambiguous findings on causation, the local retirement board approved the claimant’s application. The Public Employee Retirement Administration Commission (PERAC) intervened and appealed the decision to CRAB, arguing that the panel’s statements were insufficient to establish the required causal link. CRAB reversed the award, and the claimant sought judicial review in the Massachusetts Appeals Court.
Eligibiity for Benefits
The Massachusetts Appeals Court affirmed CRAB’s decision, finding that the panel’s failure to make an affirmative, unqualified finding of causation was fatal to the claimant’s application. The Court emphasized that under Massachusetts law, disability retirement applicants must demonstrate that the disability was substantially caused by a personal injury sustained while performing job-related duties. This showing must be supported by a clear and unequivocal medical opinion.
The Court reviewed the statutory framework under G.L. c. 32, §§ 6 and 7, and reiterated that the medical panel’s function is to provide expert findings on whether the applicant is (1) mentally or physically incapacitated, (2) incapable of performing job duties, and (3) whether the incapacity is likely permanent and related to a specific work incident. While the retirement board may weigh the panel’s findings alongside other evidence, it may not disregard a panel’s equivocal or inconclusive statement on causation and substitute its own view.
The Court held that the retirement board erred in approving the application without a definitive finding of causation from the medical panel. CRAB’s reversal was upheld as consistent with both the statutory requirements and the purpose of medical panel review, which serves as a safeguard against speculative or unsupported awards of public retirement benefits.
Speak With a Massachusetts Workers’ Compensation and Disability Attorney
Workers’ compensation often claims hinge on the strength and clarity of medical evidence. If a medical panel issues a qualified or uncertain opinion on causation, your benefits may be denied. Attorney James K. Meehan understands the legal standards governing workers’ compensation claims and can help you gather persuasive evidence and advocate for your eligibility for benefits. Contact the Law Office of James K. Meehan at 508-822-6600 or reach out through our online form to schedule a confidential consultation.