Massachusetts Court Discusses Evidence Needed to Show a Termination of Workers’ Compensation Benefits Was Improper

Workplace injuries are common, and in many instances, they render the injured parties unable to work. Frequently, however, people injured at work are entitled to workers’ compensation benefits. Generally, such benefits continue until an employee’s injuries resolve. In cases in which it is disputed whether symptoms are work-related, an employee’s disability benefits may be terminated, however. Recently, a Massachusetts appellate court discussed what an employee alleging workers’ compensation disability benefits were wrongfully ended must prove in order for the benefits to be reinstated. If you were injured at work, it is in your best interest to speak to a skilled Massachusetts workers’ compensation attorney regarding what benefits you may be owed.

Factual Background

It is reported that the claimant, who was a librarian for a law firm, suffered a back injury while working in March 2014. She began attending physical therapy in June 2014, which caused her to miss two days of work, and left work permanently in December 2014. Due to her injury, she sought and received disability benefits from her employer’s workers’ compensation insurer.

Allegedly, in September 2015, the claimant’s employer filed a complaint asking to terminate the claimant’s disability benefits. Following a hearing in October 2016, an administrative judge found that the claimant was totally disabled from December 2014 through December 2015, and partially disabled from December 2015 through September 2016, but that any disability after that time was not work related. Thus, her benefits were discontinued. The claimant appealed, and a reviewing board affirmed, after which the claimant appealed to State appellate court.

Establishing a Termination of Disability Benefits was Arbitrary or Capricious

On review, the appellate court noted that a court reviewing a decision of the reviewing board of the Department of Industrial Accidents (the board) may only set aside the board’s decision if it is capricious and arbitrary. The court further explained that a decision will not be deemed capricious or arbitrary if it is based on sufficient factual and evidentiary support and sets forth reasoned decision making within the particular requirements governing a workers’ compensation dispute. In a similar vein, a court will not find that the board has abused its discretion unless it is evident that the board has made a clear error of judgment in assessing the factors pertaining to the decision, in that the decision falls outside of the scope of reasonable alternatives.

In the subject case, the court found that the claimant failed to show her right to relief pursuant to the applicable standards. Instead, the court held that the administrative judge was justified in deeming the claimant partially disabled from December 2015 through September 2016, as he relied on evidence from an independent medical examiner and the claimant’s treating physician. The court also found that the administrative judge’s ruling that the claimant was no longer disabled, which was based on the same evidence, was proper. As such, the court affirmed the board’s decision.

Meet with an Experienced Massachusetts Attorney

If you suffered a workplace injury, you may be entitled to workers’ compensation benefits and should speak to an experienced Massachusetts workers’ compensation attorney regarding your rights. The trusted attorneys of the Law Office of James K. Meehan can advise you of what benefits you may be owed and assist you in striving to seek the full amount of benefits recoverable. You can reach us at 508-822-6600 or through the form online to schedule a consultation.