Massachusetts Court Discusses Res Judicata in Workers’ Compensation Claims

In Massachusetts, people hurt while working will typically seek workers’ compensation benefits. While employees that sustain work-related injuries can generally recover such benefits, different rules apply for land-based and water-based employees. Thus, an employee cannot recover benefits under both sets of rules, as explained in a recent Massachusetts case. If you were hurt at work, it is in your best interest to talk to a Massachusetts workers’ compensation attorney about what steps you can take to protect your interests.

History of the Case

It is reported that the plaintiff worked for a shoreside employer in Maine. The employer owned and used a fleet of vessels for marine transportation and construction. The plaintiff suffered an injury on the job and subsequently filed a claim for workers’ compensation benefits. The claim was settled with the understanding that the worker was considered a land-based employee rather than a maritime employee, although this issue was never litigated.

Allegedly, the plaintiff then filed a complaint against the employer, seeking compensation for injuries under the Jones Act and general maritime law for unseaworthiness and maintenance and cure. Alternatively, the worker sought compensation under a section of the Longshore and Harbor Workers’ Compensation Act (LHWCA), which allows certain land-based maritime workers to bring negligence actions against their employer in its capacity as the vessel owner. The employer filed a motion for summary judgment.

Res Judicata in Workers’ Compensation Claims

The court noted that the plaintiff filed a complaint asserting claims against the defendant for negligence under the Jones Act, as well as claims for unseaworthiness and maintenance and cure under general maritime law. These claims are based on the plaintiff’s alleged status as a “seaman” rather than a land-based maritime worker.

The defendant argues that the settlement of the plaintiff’s workers’ compensation claim, approved by the Maine Workers’ Compensation Board, bars the plaintiff’s claim as a seaman under the principle of res judicata. Additionally, the defendant contends that even if res judicata does not apply, the undisputed facts establish that the plaintiff was a land-based employee and not a seaman during their employment. Therefore, the defendant asserts that it is entitled to judgment as a matter of law regarding the plaintiff’s claims.

The court found that the Board’s award of workers’ compensation benefits effectively determined that the plaintiff was not a seaman, thereby barring their current claim under the Jones Act and general maritime law. The court recommends granting the defendant’s motion for summary judgment on these claims.

However, if the issue of the plaintiff’s status were to be addressed, it would require resolution by a finder of fact at trial. The court applies the doctrine of res judicata, which gives a state-court judgment the same preclusive effect as under state law, and determines that the Board’s approval of the Consent Decree precludes the plaintiff from asserting their seaman status in this case. The court concluded that all the requirements for the application of res judicata have been met and therefore granted summary judgment to the defendant.

Meet with an Experienced Massachusetts Attorney

People harmed at work can recover workers’ compensation benefits in many cases, but they generally cannot recover such benefits from multiple entities. If you were harmed at work, it is prudent to meet with an attorney to assess your rights. James K. Meehan of the Law Office of James K. Meehan is an experienced Massachusetts workers’ compensation attorney, and if you hire him, he will advocate zealously on your behalf. You can contact Mr. Meehan to set up a conference by using the form online or by calling him at 508-822-6600.