Massachusetts Court Discusses What Constitutes Work-Related Harm

People who suffer injuries during the course and scope of their employment can often recover benefits for their medical expenses under the Massachusetts Workers’ Compensation Act (the Act). Notably, the act covers harm that occurs during the performance of any normal job duties, even if they seem atypical. This was demonstrated in a recent Massachusetts case in which the court affirmed an employee’s right to recover workers’ compensation benefits after she was injured working as a chaperone on a ski trip. If you were injured on the job, it is prudent to contact a Massachusetts workers’ compensation lawyer to talk about your options.

History of the Case

It is reported that the plaintiff, who was a math teacher at the defendant’s high school, suffered injuries in a ski accident while serving as a chaperone for a high school ski club trip. The plaintiff then sought workers’ compensation benefits for her medical costs. The defendant argued that the plaintiff’s injury was not compensable as it happened when she was voluntarily participating in a recreational activity. The Department of Industrial Accidents’ reviewing board granted benefits to the plaintiff. In doing so, the Board found the recreational aspect of acting as a chaperone was secondary to her duties of monitoring the behavior of the students and ensuring they were safe. The city appealed.

Work-Related Activities Under the Act

On appeal, the court affirmed the board’s decision, emphasizing that a teacher acting as a chaperone for a school-sponsored activity is within the course of employment and not engaged in “recreational” activity under the Act. Examining the facts of the case, the court noted that the school-sanctioned ski club had been operating for years, with teachers serving as chaperones without direct financial compensation.

Supervising students during ski trips involved responsibilities such as enforcing school rules and ensuring safety, akin to regular duties within the school building. Chaperones, though volunteers, were expected to ski with students for effective supervision. The court applied Moore’s Case factors, emphasizing the customary nature of the activity, encouragement by the city, and the benefit to the employer. The board’s decision was considered in light of its authority, and the court gave substantial deference to the board’s interpretation of workers’ compensation law.

Further, the court rejected the city’s argument that the plaintiff’s injury was not compensable because it arose during an athletic event, noting that the exclusion did not apply to injuries incurred while performing normal job duties at an event substantially benefiting the employer. As the plaintiff’s injury arose out of and in the course of her employment, the court affirmed the board’s decision to award workers’ compensation benefits.

Talk to a Capable Massachusetts Attorney

People hurt while performing typical job duties can typically seek workers’ compensation benefits for their medical expenses. If you were hurt at work, it is important to speak to an attorney as soon as possible to avoid waiving important rights. James K. Meehan of the Law Office of the Law Offices of James K. Meehan is a capable Massachusetts workers’ compensation attorney who can assess your harm and aid you in seeking any benefits you may be owed. To contact Mr. Meehan to arrange a consultation, you can use the online form or call him at 508-822-6600.