Massachusetts Court Discusses Liability in the Context of Workers’ Compensation

In Massachusetts, if a person dies because of a work-related accident, the person’s family members can generally cover workers’ compensation benefits. The exclusivity provision of the Massachusetts Workers’ Compensation Act (the Act) extends to a deceased workers’ estate, however, which means that the estate cannot pursue civil claims against the deceased workers’ employer. In some instances, though, it may not be clear whether an employment relationship existed between a company and a deceased worker. Recently, a Massachusetts court discussed the test for determining whether a part is immune from liability under the Act in a matter in which the decedent died in a trucking accident while working. If you lost a loved one due to a work-related accident, you might be owed benefits, and it is smart to meet with a knowledgeable Massachusetts workers’ compensation attorney as soon as possible.

The Facts of the Case

It is reported that the decedent was resting in the sleeper compartment of a commercial truck when the truck driver crashed into another tractor-trailer that was stopped on the highway. The decedent died due to the injuries sustained in the crash. Both the decedent and the driver of the truck worked for the defendant company. The driver was an independent contractor of the defendant company and entered into a lease agreement with the company, through which he obtained the right to use the truck.

Allegedly, the driver also entered into an agreement with a staffing company through which he “leased” driver trainees, such as the decedent, who could assist him in transporting freight. Pursuant to the staffing lease agreement, the driver was responsible for the conduct and supervision of leased drivers. Following the decedent’s death, his estate received workers’ compensation benefits from the staffing company. They then filed a wrongful death lawsuit against the defendant driver’s estate and the defendant company. The defendant driver’s estate moved for summary judgment, arguing the estate’s claims were barred by the exclusivity provisions of the Act.

Determining Whether an Employment Relationship Exists

Pursuant to the Act, workers’ compensation benefits are the exclusive remedy for harm suffered during the course of employment. Although the Act prohibits the recovery of civil damages from an employer, it permits the recovery of such compensation from a third party. To evaluate whether a party is immune from liability under the Act, the courts employ a two-part test. First, they ask whether there was a direct employment relationship between the worker and the party claiming immunity.

Second, they assess whether the party claiming immunity is an insured party liable for paying workers’ compensation. In the subject case, the court found that both factors weighed in favor of the existence of an employment relationship between the driver and the decedent. As such, it granted the defendants’ motion.

Speak to a Trusted Massachusetts Workers’ Compensation Attorney

Thousands of people die in work-related deaths each year, and in most instances, their families can recover workers’ compensation death benefits. If you lost a loved one in a work accident, it is advisable to speak to an attorney regarding your rights. James K. Meehan of the Law Office of James K. Meehan is a trusted Massachusetts workers’ compensation lawyer who can advise you of your options and aid you in seeking any benefits available.  You can reach Mr. Meehan through the form online or by calling him at 508-822-6600 to set up a conference.