Angiulo: Employee Injuries and Employer Liability
Monday, September 07, 2015
In the recent case of Molina v. State Garden, Inc. the Massachusetts Appeals Court looked at these laws in the context of staffing companies. Consider that a staffing company finds people who want to work and, in this case, a produce company needs labor for processing their product. The produce company contracts with the staffing company and people show up to provide services and get paid.
The Molina case focuses on an easily occuring scenario. When a member of this temporary labor force is injured on the job, how is that laborer going to be compensated for the injury? The Appeals Court ruled that Workers' Compensation was the exclusive remedy and took the time to explain why.
Even though the produce company in this case was paying the wages and setting the hours, the staffing company was also responsible for certain aspects of the administrative concerns regarding the plaintiff and therefore was also an employer. Relevant to this case was the staffing agencies maintenance of a workers' compensation insurance policy that encompassed the produce company's relationship with the plaintiff.
In addition, when the plaintiff contracted with the staffing agency he had signed an agreement. The terms of that agreement included a promise that, if injured, the plaintiff would not sue any client of the staffing agency. That promise was based on the plaintiff acknowledging the Massachusetts Workers' Compensation statutes would be his only source of relief in a worst case scenario.
When the plaintiff was, unfortunately, injured he filed suit against the produce company claiming that there was a seperate action for negligence. The trial court allowed the produce company's pre-trial motion to dismiss, known as a summary judgment motion, based on the existence of an agreement between the staffing and produce companies to pay worker's compensation benefits.
On appeal, the justices appreciated the fact that there was no previous case directly on point. They agreed with the trial court's logic, however, because of the historical purpose of the relevant statutes, the agreement between the employers, and the availability of an insurance policy to compensate the injured worker. That the employee had signed a promise to receive such benefits and not sue the produce company did not help his case either.
As the justices of the Appeals Court pointed out, the Workers' Compensation laws were instituted to replace the pre-existing system of individual lawsuits between employers and employees. While there is still a hearing process involving an administrative agency of the Commonwealth of Massachusetts before benefits may be collected, there is an orderly process to apply and receive the appropriate compensation for injuries. While this case provides clear expectations for employers, they should remember that the properly structured relationship between the staffing and produce companies were one key to the court's analysis.
- Angiulo: SJC Says Marijuana Cultivation Alone is Not Proof of Crime
- Angiulo: Drug Dogs, Traffic Stops and the U.S. Supreme Court
- Angiulo: SJC Makes Adoption Easier For Same Sex Parents
- Angiulo: When is a Business Owner Responsible For a Customer’s Injury?
- Angiulo: Unringing the Bell of Falsified Drug Tests
- Angiulo: SJC Affirms Juvenile Suspects’ Rights During Interrogation
- Angiulo: A Generation of Employees Just got Squeezed a Little Harder
- Angiulo: New SJC Decision on the Individual’s Second Amendment Right
- Angiulo: Statutes of Limitation and the Need to Take Action
- Angiulo: No Matter Who the Defendant is the Law Remains the Same
- Angiulo: Personal Injury, Insurance Companies & the Obligation to Settle Clear Cases
- Angiulo: Drug Convictions, Firearms and the Supreme Court
- Angiulo: Elder Abuse, Powers of Attorney and Harassment Prevention Orders
- Angiulo: Drunk Driving Charges and Commercial Driver’s License Suspensions
- Angiulo: An Insurance Agent at the Intersection of Business Model and Criminal Act
- Angiulo: Freedom of Speech and Political Campaigns
- Angiulo: Challenging the Legality of Motor Vehicle Stops by Police
- Angiulo: Overtime Pay for Employees and Employer Obligations
- Angiulo: SJC Looks at Mortgage Foreclosure Process in Massachusetts
- Angiulo: Land of the Free, Home of Live Nude Dancing
- Angiulo: SJC Says Breath Tests in Massachusetts Are in Question
- Angiulo: Supreme Court Decides When Online Threats Become Criminal Acts
- Angiulo: SJC Defines the Limits of Parental Discipline
- Angiulo: The Supreme Court, the Death Penalty, and the Constitution
- Angiulo: Sometimes a Spouse Really Does Get Half Your Stuff in a Divorce