Massachusetts Court Discusses Jurisdiction Over Out of State Injuries in Workers’ Compensation Claims

Massachusetts employees who are hurt while working are often eligible to recover compensation. There are certain prerequisites that must be met for harm to be compensable, however, and an employee that cannot demonstrate an injury is work-related may be denied benefits. Recently, a Massachusetts court addressed the issue of whether harm is compensable if neither the injury-inducing accident nor the signing of the employment contract occurred in the Commonwealth. If you work for a Massachusetts company and were hurt at work, it is in your best interest to speak to a seasoned Massachusetts workers’ compensation attorney to determine whether you may be owed damages.

The Plaintiff’s Harm

It is reported that the plaintiff responded to the defendant’s advertisement for truck drivers that as posted in a Massachusetts newspaper. He then attended training at the defendant’s headquarters in Pennsylvania and signed an employment contract while he was there. Once he began working for the defendant, he delivered cargo throughout the northeastern states, including Massachusetts. He also made over one hundred trips to or from Massachusetts, which was more time than he spent in any other state.

Allegedly, the plaintiff suffered an injury while delivering cargo in Maine. He filed a claim for workers’ compensation benefits pursuant to the Massachusetts Workers’ Compensation Act (the Act). An administrative judge found that he suffered work-related harm but dismissed his claim regardless on the basis that Massachusetts was not the place where the plaintiff was hired or injured, and therefore the court lacked jurisdiction. The case went through numerous rounds of appeals and was ultimately presented to the Supreme Judicial Court of Massachusetts.

Proving the Location of Employment

The court noted that the Act is a remedial statute that should be interpreted broadly and viewed in light of its purpose to provide injured employees with benefits. While the Act states that it applies to employees who suffer work-related harm either in or outside of the Commonwealth, it does not specify its jurisdictional limits. The court stated, though, that the language in the Act stating it applied to out of state injuries was meant to enlarge rather than restrict its scope.

The court went on to say that the basis of the provision is the Commonwealth’s interest in avoiding the unfortunate consequence of a worker who lives in Massachusetts but suffered injuries in another state being unable to recover workers’ compensation benefits. The court explained it had previously interpreted the applicable provision to grant Massachusetts jurisdiction over claims where employment contracts were made in Massachusetts, even if the injury occurred elsewhere. Similarly, the court had found the exercise of jurisdiction over claims involving injuries that occurred in Massachusetts but involved out of state employment contracts to be proper.

In the subject case, the court found that the lower courts took the narrowest approach possible in interpreting the Act. In light of the goals of the Act, however, the court found that a broader interpretation was necessary. Thus, the court ruled that whether Massachusetts could exercise jurisdiction over a workers’ compensation claim depended on the injured employee’s contacts with the state. Here, the court found the contacts to be sufficient to render the exercise of jurisdiction proper. As such, the lower court ruling was vacated, and the matter was remanded for further proceedings.

Meet with a Trusted Massachusetts Attorney

People who are hurt while working in Massachusetts are often eligible to recover workers’ compensation benefits and should explore their options. If you were injured in a work-related accident, the trusted Massachusetts workers’ compensation attorneys of the Law Office of James K. Meehan, can advise you of your rights and help you seek to recover any benefits you may be owed. You can reach us via our online form or at 508-822-6600 to set up a meeting.