Massachusetts Supreme Judicial Court Rules that Suspended Employees are Eligible for Workers’ Compensation

Massachusetts workers’ compensation laws are largely statutory creations, and therefore, sometimes Massachusetts courts are asked to interpret statutory meanings. The Supreme Judicial Court recently decided a case that required the interpretation of the meaning of “compensation” under General Laws Chapter 268A, Section 1(a). The court’s ruling allows suspended employees to continue receiving payments under Massachusetts workers’ compensation laws.

The plaintiff was employed by the city of Boston as a paramedic. In 2011, he injured his right ankle while transferring a patient into an ambulance. The resulting injury required the defendant to pay workers’ compensation benefits to the plaintiff. However, the defendant terminated the payments after learning that the plaintiff was facing several criminal charges involving drugs at work. The city of Boston suspended the plaintiff’s employment in accordance with the State’s suspension statute.

The Department of Industrial Accidents reviewed the plaintiff’s workers’ compensation claim in an administrative hearing and ruled in the plaintiff’s favor. The DIA ordered the city of Boston to continue making payments to the plaintiff. The defendant refused, and the plaintiff filed a lawsuit for enforcement of the order against the city of Boston. The Superior Court dismissed the lawsuit because, in the court’s view, the suspension statute prohibited the payment of  “compensation” under General Laws Chapter 268A, Section 25, and the court viewed workers’ compensation benefits as “compensation.” After the plaintiff appealed, the Supreme Judicial Court transferred the case from the appeals court on its own motion.

The plaintiff’s litigating position was that workers’ compensation does not fall within the meaning of “compensation” under the suspension statute. For example, the suspension statute defines “compensation” as providing something of value in exchange for services rendered. Workers’ compensation payments, in the plaintiff’s view, were not being provided for services rendered.

The Supreme Court sided with the plaintiff’s position. Under the suspension statute, compensation must be provided in exchange for the employee’s services. The Supreme Court reasoned that this did not apply in the workers’ compensation framework because the compensation is being provided because of the plaintiff’s waived right to sue his or her employer in tort for injuries and the guarantee of payments when injured at work.

The Supreme Court’s decision allows suspended employees to continue receiving workers’ compensation benefits. The Supreme Court ruled that the plaintiff’s claim was dismissed in error and remanded the case to the Superior Court for further proceedings consistent with the Supreme Court’s decision.