Workers’ Compensation Claims in Massachusetts

Background

“The Commonwealth requires all employers to provide workers' compensation benefits to their employees.” (See HDH Corp. v. Atlantic Charter Insurance (1997) 425 Mass. 433, 439-40.)

“The purpose of the workers' compensation program is to ensure prompt payment for injuries in the workplace.” (See Truong v. Wong (2002) 55 Mass. App. Ct. 868, 878.)

"Our workers' compensation act sets up a system of money payments for the loss of earning capacity sustained by an employee by reason of a work-connected injury, and it should be interpreted in the light of its purpose and, so far as reasonably may be, to promote the accomplishment of its beneficent design." (See Young v. Duncan (1914) 218 Mass. 346, 349; Louis's Case (1997) 424 Mass. 136, 140.)

“We construe broadly the workers' compensation act for the protection of injured workers.” (See Wentworth v. Henry C. Becker Custom Building Ltd. (2011) 459 Mass. 768, 772.)

General Information for Complaints and Motions

“The workers' compensation law was designed to provide wage-loss protection to employees who are injured on the job and incur a loss of earning capacity from the injury.” (See Tobin's Case (1997) 424 Mass. 250, 253.)

“[I]t is established that the [workers'] compensation act is to be construed broadly, rather than narrowly, in the light of its purpose and, so far as reasonably may be, to promote the accomplishment of its beneficent design.” (See In re Wadsworth (2012) 461 Mass. 675, 687.)

“[T]he ‘beneficent design’ that the workers' compensation scheme seeks to accomplish is ‘wage replacement’ for injured employees, ... which is to be calculated on the basis of the injured employee's earning capacity.” (See id.)

“An employee ... shall ... be paid such compensation at the rate in effect at the time of the subsequent injury.” (See id.)

Prima Facie Case

“The section by its terms establishes prima facie evidence of four separate aspects of a workers' compensation claim: 

1. that the employee was performing his regular duties on the day of injury or death;
2. that the claim comes within the provisions of [c. 152];
3. that sufficient notice of the injury has been given; and
4. that the injury or death was not occasioned by the willful intention of the employee to injure or kill himself or another."

(See G.L. c. 152, subsection 7A; In re Moss's Case (2008) 451 Mass. 704, 707-08.)

“For a claim to be compensable it must arise out of and in the course of the employment.” (See id.)

“Clearly a causal relationship is required between the employment duties and the injury or death.” (See id.)

Standard of Review and Burdens of Proof

“We review a board's decision regarding workers' compensation benefits under the usual standard for appeal from a final decision of an administrative agency set forth in G.L. c. 30A, subsection 14(7), except that we do not review whether the board's decision was supported by substantial evidence.” (See In re Wadsworth (2012) 461 Mass. 675, 679.)

“We may reverse or modify the board's decision where it is based on an error of law, or is arbitrary or capricious.” (See id.)

“Where the board reverses an administrative judge based on a finding of fact, we must determine whether the board was arbitrary or capricious in concluding that the administrative judge was arbitrary or capricious.” (See id.)

“The board, as the agency charged with administering the workers' compensation law, is entitled to substantial deference in its reasonable interpretation of the statute.” (See id.)

The Court’s Decisions

It is well settled that “one aim of the Workmen's Compensation Act is that there be speedy payment of the amount due an injured employee. Payments under the Act were meant to provide financial relief for the injured employee's inability to earn wages or for the deprivation of support flowing from wages the employee had previously received.” (See Brown v. Leighton (1982) 385 Mass. 757, 763.) 

It is also well settled that “the fundamental purpose of the workers' compensation system is to make funds more readily available to injured employees.” (See HDH Corp. v. Atlantic Charter Insurance (1997) 425 Mass. 433, 439.)