It is well-established that the Massachusetts Workers’ Compensation Act (the Act) supplants an employee’s right to pursue civil claims against their employer for harm that arises in the workplace with the right to recover workers’ compensation benefits for said harm. It is not always clear, however, what claims the exclusivity provision of the Act actually prohibits. Recently, a Massachusetts court analyzed the scope of the provision in a case in which it ultimately found that the Act barred the plaintiff’s claims. If you suffered a physical or mental injury because of conditions you encountered in the workplace, it is prudent to confer with a Massachusetts workers’ compensation attorney to discuss what steps you should take to protect your interests.
The Facts of the Case
It is alleged that the plaintiff filed a civil lawsuit against the defendant, her employer, seeking damages for harm caused by the conditions of her employment, which she alleged were unlawful. She asserted six causes of action against the defendant, including two emotional distress claims. The defendant moved for the dismissal of the plaintiff’s complaint.
Conduct that Occurs Within the Scope of the Employment
In its motion to dismiss, the defendant argued that the plaintiff’s emotional distress claims were barred by the exclusivity provision of the Act. In response, the plaintiff countered that the conduct that she complained of in her complaint did not fall within the scope of employment, and as such, the exclusivity provision of the Act did not preclude her claims. Specifically, the plaintiff asserted that intentional torts that fail to further the interests of an employer do not fall within the scope of employment, and directing an employee to engage in illegal activity certainly cannot further an employer’s interests.
The court noted that the Act prohibits employees from pursuing tort claims against their employers in cases in which the employee did not expressly preserve their right to pursue such claims. In other words, the Act was enacted to replace tort claims by offering injured employees a uniform statutory remedy in place of a piecemeal tort system. The court clarified that the exclusivity provision of the Act should be construed broadly to preclude any civil claims for emotional injuries that arise in and out of the course of employment.
An injury will be deemed to arise out of the course of employment if it is brought about by the conditions, nature, or obligations of the employment. As such, even if tortious behavior is motivated by personal interests, it usually falls within the scope of employment unless the motivation for such behavior is purely personal. In the subject case, the court found that the acts the plaintiff complained of occurred within the scope of employment. Thus, it barred her emotional distress claims.
Meet with a Trusted Massachusetts Attorney
People hurt by their coworkers can often recover workers’ compensation benefits but are precluded from pursuing other damages, even if their harm was caused by tortious conduct. If you sustained losses at work due to the acts of your coworker, it is in your best interest to confer with an attorney to determine your rights. James K. Meehan of the Law Office of James K. Meehan is a trusted Massachusetts workers’ compensation attorney who is well-versed in what it takes to achieve successful outcomes in workers’ compensation cases, and if you hire him, he will diligently pursue any available benefits on your behalf. You can get in touch with Mr. Meehan by using the form online or by calling him at 508-822-6600 to set up a consultation.