Decision to Deny Line-of-Duty Benefits to State Trooper Reversed as Ad Hoc, Per Massachusetts Appeals Court

Most workers who are injured on the job are entitled to some type of compensation. For example, a Cape Cod workers’ compensation claimant may pursue medical treatment, temporary disability, or permanent disability benefits, depending upon the nature and resolution of his or her injuries.

Some types of workers are limited to benefits under a particular law or statute. This includes members of the state police, such as state troopers. An appeals court was recently asked to review the rights of a trooper who hurt his back while working.

Facts of the Case

In a case heard recently by the Commonwealth of Massachusetts Appeals Court, the plaintiff was a state trooper who sought line-of-duty (ILD) injury benefits after he allegedly injured his back while reaching into the passenger side floor of his cruiser to retrieve a clipboard that had fallen off the seat. The trooper notified his commanding officer and sought medical care. Initially, it appeared that the trooper’s ILD request would be approved, but the state police department’s board on claims ultimately rejected the claim, based on a doctor’s conclusion that the trooper’s back pain was due to pre-existing conditions rather than a work-related injury.

The trooper appealed the board’s decision to the colonel, but the colonel sustained the board’s decision and denied the trooper’s request for ILD benefits. The trooper further appealed to the superior court, which found that the trooper’s sciatica was an injury, rather than a symptom, and was compensable. The defendant state police sought review from the Massachusetts Appeals Court.

Decision of the Court

The appellate court affirmed on different grounds. Noting that there were limited reasons for disturbing a colonel’s decision regarding ILD benefits under Massachusetts General Laws ch. 22C, § 43, the court found that the board’s decision, which was approved by the colonel, was arbitrary and capricious because it appeared to be a result of ad hoc reasoning. As a result, it could not stand.

The court so held after finding that the department’s rules and regulations concerning the limitation of ILD benefits to injuries “incurred” or “sustained” in the line of duty could be interpreted – at the board’s whim – to either allow or disallow claims such as the trooper’s in which a worker was hurt on the job, but the injury caused a new disability from a pre-existing, dormant medical condition. In so holding, the court noted that such claims were compensable under Massachusetts’ general workers’ compensation laws as long as the work injury was a major cause of the claimant’s disability.

Need to Talk to a Lawyer About a Cape Cod Work Injury?

If you’ve been hurt at work, it pays to talk to an experienced Cape Cod workplace accident attorney about your legal rights as soon as possible. This is true even if you believe that your employer is “doing the right thing” at the moment; there are many technical requirements and procedural hurdles to be considered in these types of cases, and failing to seek legal representation early on could adversely affect your case later. To make sure your rights are protected, call 888-262-6664 to schedule an appointment at the Law Offices of John C. Manoog, III, in Hyannis or Plymouth.

Related Blog Posts: Massachusetts Appeals Court Affirms Temporary Total Disability Award to Nurse Who Was Hurt at Work Massachusetts Appeals Court Affirms Permanent, Total Disability Award in Workers’ Compensation Case