Massachusetts Injury Lawyers Blog
In workers’ compensation cases, a claimant must establish that a workplace injury is the predominant cause of their disability. Disputes over causation often hinge on medical evidence and the credibility of expert testimony. A recent decision by a Massachusetts court highlights the legal standards that apply when a worker alleges permanent disability from multiple injuries over time. If you are struggling to obtain benefits following a work-related injury, a Massachusetts workers’ compensation attorney can help protect your rights and advocate for the benefits you deserve.
Factual Background and Procedural History
It is reported that the plaintiff, a veteran employee of a Massachusetts sheriff’s department, suffered a series of injuries while working as a correctional officer. These injuries included incidents in 2006, 2008, and 2011 involving falls, physical altercations with inmates, and repeated trauma to the knees and back. The plaintiff received workers’ compensation benefits for these injuries and eventually applied for accidental disability retirement, citing cumulative physical deterioration from the job as the reason for his permanent inability to work.
It is alleged that a regional medical panel evaluated the plaintiff and concluded that he was permanently disabled, but the panel could not unanimously agree that the disability was substantially caused by work-related incidents. Despite this lack of consensus, the plaintiff’s application was approved by the retirement board, which found that the work injuries were a major contributing factor to his current condition. The Public Employee Retirement Administration Commission (PERAC) intervened and appealed the board’s decision, asserting that the causation evidence was insufficient.
It is further reported that the Contributory Retirement Appeal Board (CRAB) sided with PERAC, reversing the award. CRAB concluded that the medical evidence was speculative and did not establish that the work injuries were the predominant or natural cause of the plaintiff’s disability. The plaintiff appealed, arguing that CRAB improperly rejected the panel’s findings and substituted its own medical judgment.
Proving an Injury is Work Related
The Massachusetts Appeals Court upheld CRAB’s decision, emphasizing that disability retirement applicants must prove that a specific work injury or series of injuries is the “natural and proximate cause” of their permanent disability. This standard requires more than a mere association between the work and the disability; it demands persuasive, non-speculative medical evidence linking the two.
The court found that the medical panel’s failure to reach a unanimous conclusion on causation significantly undermined the plaintiff’s case. Moreover, it noted that while the retirement board may accept a minority medical opinion in some circumstances, it must articulate clear reasons for doing so and rely on credible supporting evidence. In this case, the board’s reliance on ambiguous or inconclusive medical reports was not sufficient to satisfy the statutory burden.
Importantly, the court reaffirmed that CRAB has the authority to evaluate the sufficiency and credibility of medical evidence and is not bound by the retirement board’s factual findings when the evidence does not support them. The court found no legal error in CRAB’s conclusion that the plaintiff had failed to prove the required causal link.
Speak With a Massachusetts Workers’ Compensation and Disability Attorney
Winning a disability retirement or workers’ compensation claim in Massachusetts requires clear, consistent medical evidence and a solid understanding of the legal standards for causation. If you are seeking workers’ compensation benefits after a workplace injury or believe your claim has been wrongly denied, Attorney James K. Meehan can help. Contact the Law Office of James K. Meehan at 508-822-6600 or reach out through our online form to schedule a confidential consultation.