Massachusetts Court Discusses When Workers’ Compensation Exclusivity Bars Claims

Families who lose a loved one in a workplace accident often feel a natural desire to pursue justice through the courts. Yet, under Massachusetts law, many of these claims are barred by the exclusivity provisions of the Workers’ Compensation Act. These provisions are designed to ensure uniform remedies but can sometimes leave families with no recourse against an employer, even in heartbreaking circumstances. A recent decision from the Supreme Judicial Court illustrates just how far this exclusivity rule extends. If you or a loved one has suffered harm at work, it is critical to understand how workers’ compensation law affects your rights, and you should consult an experienced Massachusetts workers’ compensation attorney about your options.

History of the Case

It is alleged that the decedent, an 18-year-old high school student working at a Boston pharmacy, attempted with other employees to stop a suspected shoplifter. Reportedly, the suspect responded with sudden violence, stabbing the decedent in the neck and causing fatal injuries almost instantly.

Allegedly, the decedent had no dependents, though he lived with his mother and was financially connected to both of his parents. Because he left no dependents, no workers’ compensation death benefits were paid, aside from funeral expenses voluntarily covered by a related corporation.

It is reported that the decedent’s parents filed a wrongful death lawsuit, seeking damages for loss of consortium and punitive damages against the employer. The employer moved to dismiss, asserting that the Workers’ Compensation Act barred the claim under its exclusivity provisions. The trial court agreed, and the parents appealed.

Workers’ Compensation Exclusivity in the Context of Wrongful Death

On review, the court considered whether the exclusivity provision of the Workers’ Compensation Act applied when an employee dies during the course of employment, but no compensation is payable because there are no dependents. The parents argued that, since no benefits were received, the exclusivity rule should not prevent their wrongful death claim.

The court rejected this reasoning. It explained that what matters is not whether compensation is actually paid, but whether the injury is the type covered by the Act. Under the statute, an injury is considered compensable if it arises out of and in the course of employment. Here, the decedent’s death clearly met that definition. Because the injury was compensable, the exclusivity provision applied, blocking the parents’ wrongful death claim.

The court further emphasized that allowing recovery outside the Act in such situations would undermine the legislative scheme. The workers’ compensation system is intended to provide uniform, predictable remedies for work-related injuries, while protecting employers from tort liability. Conditioning the Act’s applicability on the payment of benefits would open the door to inconsistent outcomes and unnecessary litigation.

The parents also contended that barring their claim violated constitutional protections by denying them a remedy for the loss of their son. The court disagreed, noting that the Legislature has the authority to redefine or eliminate common-law remedies as part of a statutory compensation system. Ultimately, the court affirmed the dismissal of the parents’ lawsuit, holding that the exclusivity rule barred their claims despite the absence of workers’ compensation payments.

Confer with a Seasoned Workers’ Compensation Massachusetts Attorney

Families may understandably want to pursue claims against an employer after a tragic workplace death, but the law often prevents such actions, even when benefits are unavailable. If you or someone close to you has been injured or killed in a workplace accident, it is crucial to speak with an attorney who can explain your rights and help you navigate the complex rules of the workers’ compensation system. James K. Meehan of the Law Office of James K. Meehan is a seasoned Massachusetts workers’ compensation attorney who can advocate for your best interests and help you pursue the compensation and benefits you are entitled to. You can reach Mr. Meehan by calling 508-822-6600 or by filling out the online form to schedule a consultation.