Massachusetts Court Discusses Evidence Needed to Show Harm is Work-Related

Generally, when public employees suffer injuries in a work incident that renders them unable to work, they can seek accidental disability retirement benefits. If their employer argues that the harm in question predated their accident, however, it may be challenging for them to recover benefits. Recently, a Massachusetts court discussed what evidence is needed to demonstrate harm is work-related rather than the result of a pre-existing condition. If you were hurt at work, it is wise to talk to a Massachusetts workers’ compensation attorney about your rights.

Case Background

It is alleged that the claimant, who worked for the city of Worcester, applied for accidental disability retirement benefits due to a psychiatric condition stemming from a traumatic brain injury sustained during a fall from a garbage truck. The medical reason for the application was attributed to depression that was caused by a head injury. A regional medical panel comprised of three doctors affirmed the claimant’s incapacity to perform job duties, the permanence of this incapacity, and its link to the injury. The panel’s narrative noted the worsening of the claimant’s condition following the head injury and diagnosed him with major depressive disorder and neurocognitive disorder due to traumatic brain injury.

Reportedly, though, the Worcester Retirement Board rejected the claimant’s application. The case was brought before a Division of Administrative Law Appeals magistrate, who, after considering medical reports and testimony from the claimant, concluded that he was eligible for accidental disability retirement benefits. Despite adopting most of the DALA magistrate’s findings, the Contributory Retirement Appeal Board (CRAB) rejected the conclusion on medical causation and asserted that the claimant’s psychiatric conditions were continuous with his pre-existing conditions. The claimant appealed, and the court reversed CRAB’s decision. CRAB then filed an appeal.

Demonstrating Harm is Work-Related

On appeal, the court affirmed the lower court ruling in favor of the claimant. In doing so, it noted that CRAB’s rejection was rooted in a misinterpretation of medical evidence and reliance on extra-record sources. Specifically, CRAB disputed the panel’s assertion that the claimant had not received psychiatric treatment prior to the injury, based on external online sources, which was deemed impermissible. Moreover, CRAB cited the report of a single doctor who did not address the depression symptoms, leading to an erroneous conclusion. CRAB also focused on changes in the claimant’s account of the accident and questioned the validity of his claim of losing consciousness despite the DALA magistrate’s credibility assessment.

The court noted that CRAB’s emphasis on unrelated stressors as causes of depression was unsupported by medical records, and their claim that certain factors were withheld from the regional medical panel was debunked by the panel’s access to comprehensive medical reports.

Furthermore, the court found that CRAB applied the incorrect standard for proving a permanent inability to perform duties and, ultimately, failed to provide sufficient grounds for rejecting the DALA magistrate’s findings on causation. Consequently, the court affirmed the lower court judgment, which favored the claimant.

Confer with an Experienced Massachusetts Attorney

Employers will often try to avoid paying injured employees the benefits they are owed, but if an employee demonstrates their harm is work-related, their claim should not be denied. If you sustained harm at work, you may be owed benefits, and it is smart to confer with an attorney. James K. Meehan of the Law Office of James K. Meehan is an experienced Massachusetts workers’ compensation lawyer who can inform you of your rights and help you to seek just results. You can reach Mr. Meehan to schedule a meeting through the form online or by calling him at 508-822-6600.