Massachusetts Court Discusses Joint Ventures in Workers’ Compensation Claims

The Massachusetts Workers’ Compensation Act is the sole remedy for employees who suffer injuries, which means they have the right to recover benefits but are generally precluded from pursuing civil lawsuits against their employers. They can seek damages via civil claims against other parties, however. In some instances, a party will attempt to avoid liability by arguing it engaged in a joint venture with the employer of the injured individual. Recently, a Massachusetts court discussed joint ventures in the context of workers’ compensation claims, in a matter in which the plaintiff was denied the right to recover damages. If you suffered harm at work, it is advisable to speak to a trusted Massachusetts workers’ compensation attorney to discuss your rights.

Facts of the Case

It is alleged that the plaintiff suffered injuries while working for his employer, a chain steakhouse. He filed a workers’ compensation claim and received benefits that listed the two defendant companies and the chain steakhouse as insureds. He then filed a civil lawsuit against the two defendant companies, alleging negligence.

Reportedly, the defendants filed an answer arguing that the plaintiff’s claims were barred by the Massachusetts Workers’ Compensation Act (the Act). The case proceeded to trial, and the jury found that the defendants were engaged in a joint venture with the plaintiff’s employer. As such, the plaintiff’s claims were barred by the Act. The plaintiff filed a motion for a judgment notwithstanding the verdict, but the court denied her motion. She then appealed.

Determining Whether a Joint Venture Exists

The appellate court explained that the plaintiff’s claims turned on whether the parties were engaged in a joint venture and therefore were considered a single employer under the Act. A joint venture resembles a partnership and has many of its attributes. Typically, but not always, it is limited to a single enterprise, and the relationship of joint venturers is a matter of intent that only arises when they intend to regard themselves as such.

Whether two or more entities are engaged in a joint venture and therefore are considered a joint employer is a mixed question of fact and law. The mere fact that entities have common shareholders and management in and of itself is not sufficient to demonstrate a joint enterprise. Proof of an intent to constitute a joint venture may include an agreement to associate for joint profit, joint property interests, and a duty to share losses. In the subject case, the appellate court found that there was ample evidence by which a reasonable jury could find the defendants were engaged in a joint venture with the plaintiff’s employer. Thus, it affirmed the trial court ruling.

Speak to an Experienced Massachusetts Attorney

People who suffer harm in the workplace can often recover workers’ compensation benefits from their employers, but in some instances, it may not be clear who qualifies as an employer. If you sustained injuries at work, it is in your best interest to speak to an attorney about what benefits you may be owed.  James K. Meehan of the Law Office of James K. Meehan is an experienced Massachusetts workers’ compensation lawyer with the skills and resources needed to obtain favorable outcomes, and if you hire him, he will work tirelessly on your behalf. You can contact Mr. Meehan via the form online or by calling him at 508-822-6600 to set up a meeting.