Massachusetts Court Discusses Workers’ Compensation Immunity

Under the Massachusetts Workers’ Compensation Act, employees can recover workers’ compensation benefits if they are hurt while on the job. In exchange for that right, though, they lose the ability to pursue civil claims against their employers. Recently, a Massachusetts court addressed whether employees could bypass the exclusivity portion of the Act in cases in which the prior owner of the employer’s company was negligent, ultimately determining they could not. If you were harmed while working, it is in your best interest to speak to a Massachusetts workers’ compensation attorney promptly.

Factual and Procedural History

The plaintiff, an employee of the defendant, received workers’ compensation benefits for an injury sustained while operating a hydraulic press. The plaintiff and his wife subsequently filed a tort suit against the defendant, alleging that defects in the hydraulic press, which was owned by the prior owner before merging into the plaintiff’s employer, caused the injury. They claimed the prior owner knew about the press’s defects at the time of the merger but failed to disclose or remedy them.

Allegedly, the plaintiffs argued that the prior owner’s liability transferred to the defendant through the merger. The defendant contended that the plaintiff’s tort claims were barred by Massachusetts workers’ compensation law, as the benefits received through the law provided immunity to the employer from such suits. This case came before the court for the second time on appeal.

Workers’ Compensation Immunity Following Corporate Changes

On appeal, the court evaluated whether the plaintiffs could bypass workers’ compensation immunity due to the employer’s corporate changes. The court referred to the Massachusetts Workers’ Compensation Act, which generally bars employees from suing employers for work-related injuries while allowing suits against third parties. The court analyzed the “dual persona” doctrine, which allows an employer to be sued if it holds a completely separate legal identity from its role as an employer.

However, the court found this doctrine inapplicable, noting that Lightolier’s ownership of the press and its subsequent merger did not create separate liability. The court emphasized that the Massachusetts Supreme Judicial Court had not extended this doctrine to similar circumstances and noted the strong policy favoring the exclusivity of workers’ compensation as a remedy.

The court concluded that since Lightolier would not have been liable to the plaintiff as a third party absent the merger, the workers’ compensation immunity applied. Therefore, the court affirmed the district court’s summary judgment in favor of the defendant, ruling that the plaintiff’s tort claim was barred by the Massachusetts workers’ compensation law.

Reach out to an Experienced Massachusetts Workers’ Compensation Attorney

Massachusetts employers are required to provide workers’ compensation benefits to employees injured on the job, regardless of who is at fault. If you suffered an injury at work, it is beneficial to reach out to an attorney about the benefits you might recover. Attorney James K. Meehan is an experienced Massachusetts workers’ compensation lawyer with a wealth of experience in advocating for injured workers’ rights. To connect with Attorney Meehan, you can use our online form or call him at 508-822-6600 to schedule a confidential discussion.