Massachusetts Court Explains Tort Claims for Injured Massachusetts Workers

The Massachusetts Workers’ Compensation Act grants injured employees the opportunity to seek compensation for workplace injuries, with the trade-off being the forfeiture of their ability to pursue tort claims against their employer due to the Act’s exclusivity provision. As explained in a recent Massachusetts ruling, this exclusivity provision not only applies to employees who received workers’ compensation claims under the Massachusetts Workers’ Compensation Act (the Act), but also to those who received such benefits under similar Acts in other states. If you were hurt in a workplace accident, it is advisable to consult with a Massachusetts workers’ compensation attorney who can guide you through the available avenues for seeking benefits.

History of the Case

It is alleged that the plaintiff sustained severe leg injuries when a deteriorated garage wall collapsed on him while he was on the residential property of the defendant. The defendant had hired the plaintiff’s employer, a landscaping company, to demolish and remove her garage. Following his injuries, the plaintiff filed for workers’ compensation benefits in Rhode Island, where he resided.

Reportedly, after initially being denied benefits by the landscaping company’s insurer, the plaintiff and landscaping company reached a settlement in Rhode Island for a lump-sum payment of $19,000. As part of this settlement, the plaintiff released the landscaping company and its insurer from further liability. The settlement did not expressly cover one of landscaping company’s principals. Subsequently, the plaintiff filed a negligence lawsuit in Massachusetts against the defendant and the landscaping company’s principal. The defendants moved for summary judgment, and the court granted their motion.

Tort Claims for Injured Massachusetts Workers

On appeal, the court affirmed the dismissal of the plaintiff’s claims. Firstly, the court ruled that the plaintiff’s release of the landscaping company in the Rhode Island settlement precluded him from pursuing a negligence claim against the landscaping company’s principal in Massachusetts. The court explained that Massachusetts law, as well as Rhode Island law, recognizes that recovery for tort will not be allowed if a defendant is immune from liability under the workers’ compensation statute of the state where the injury occurred. Since the plaintiff had settled his workers’ compensation claim in Rhode Island, releasing the landscaping company, he could not bring a tort claim against its principal.

Additionally, the court ruled that the defendant owed no duty of care to the plaintiff under the circumstances. While landowners typically owe a duty of reasonable care to lawful visitors, an exception exists when the visitor is on the property to remedy a hazardous condition. In this case, both the defendant and the landscaping company were aware of the hazardous garage condition, and the plaintiff, contracted to mitigate the risk, was also aware of it. As such, the defendant was not liable for the plaintiff’s injuries.

Meet with a Trusted Massachusetts Attorney

Injuries sustained in a workplace accident can bring about both physical and financial challenges. If you were hurt at work, it’s wise to speak to an attorney about the possibility of recovering workers’ compensation benefits. James K. Meehan of the Law Office of James K. Meehan is a trusted Massachusetts workers’ compensation attorney who is adept in helping individuals seek any recoverable benefits, and if you hire him, he will vigorously advocate for your rights and interests. You can arrange a consultation with Mr. Meehan via the online contact form by calling him at 508-822-6600.