Massachusetts Appeals Court Affirms Sanctions in Worker’s Compensation Case Brought Without Reasonable Grounds

An appellate court has upheld an award of costs in a workers’ compensation case that was precluded due to res judicata.  In In Re Richards’ Case, a bank employee filed a workers’ compensation benefits claim related to the back injury she purportedly sustained while moving boxes at work in May 2005. After her claim was denied by an administrative judge, the woman ultimately appealed the case to the Court of Appeals of Massachusetts. In 2009, the appellate court affirmed the administrative judge’s decision. Instead of seeking further appellate review, however, the worker filed several additional benefits requests based on the same alleged injury. Three claims were withdrawn, and a fourth was considered at a hearing before a workers’ compensation judge.

The administrative judge found that the employee’s claim was barred by the doctrine of res judicata. In addition, the worker’s attorney was ordered to pay the full costs of the proceeding because the woman’s claim was filed without a reasonable expectation of prevailing in violation of § 14. In 2014, the Department of Industrial Accidents Reviewing Board affirmed the judge’s decision, and the woman again filed an appeal with the Court of Appeals of Massachusetts.

On appeal, the woman argued her claim was not brought “without reasonable grounds,” nor was it precluded by the doctrine of res judicata. This doctrine prohibits a legal claim that has been decided on the merits from being reconsidered. After reviewing the long procedural history in the employee’s case, the appellate court stated it was permitted to reverse the Board’s decision if it was arbitrary, capricious, or based on a legal error.

Next, the Court of Appeals examined whether the worker’s benefits claim was barred by res judicata. According to the woman, her most recent claim was not precluded because the judge in her first case found original liability on the part of her employer despite ruling she was not disabled. The appeals court disagreed and stated the administrative judge found that the woman did not sustain a workplace accident. The judge also said the worker failed to meet her burden of demonstrating otherwise. Because of this, the appellate court held the Board did not commit error when it determined the woman’s subsequent workers’ compensation request was barred by the doctrine of res judicata.

The court then dismissed the worker’s claim that the Board abused its discretion when it affirmed the judge’s legal fees award. The court said the worker’s claim was clearly brought without reasonable grounds because it rested on one sentence that was taken out of context. Additionally, the employee’s attorney was specifically warned that § 14 costs may be assessed if the worker proceeded with her case. Despite this, the court declined to double the legal fees award issued against her counsel.

Finally, the Court of Appeals of Massachusetts affirmed the Department of Industrial Accidents Reviewing Board’s decision in the workers’ compensation case.

If you sustained a significant workplace injury in Massachusetts, you may be entitled to recover workers’ compensation benefits for your harm. The dependable lawyers at Kantrovitz & Associates, P.C. are here to help you navigate the process of your workers’ compensation claim. To speak with an experienced Boston workers’ compensation attorney, contact Kantrovitz & Associates, P.C. through our website or give us a call today at 800-367-0871.

Additional Resources:

In Re Richards’s Case, Mass: Appeals Court 2015

Workers’ Compensation