Federal Court Holds Massachusetts Worker’s Emotional Distress Claims Preempted by MWCA
The Massachusetts Workers’ Compensation Act prohibits an employee from bringing a lawsuit against an employer for injuries that arise out of his or her employment. In Branyan v. Southwest Airlines Co., an airline employee apparently sustained a wrist injury while assisting a passenger in 2013. Following the incident, the worker was placed on paid leave. During this time, the airline continued providing the Halifax woman with health and other benefits. About two months later, the airline’s insurer denied the employee’s claim for workers’ compensation benefits.
Next, the airline reportedly began demanding reimbursement for the benefits paid on the worker’s behalf and charged her sick time for her absence. The airline also allegedly began requesting that the employee return to work immediately. During this time, the worker underwent surgery and purportedly directed all further communications to her attorney. After the airline made numerous calls to the worker, it eventually requested that local police perform a wellness check on her. Three days later, the worker was notified that her employment was terminated.
In late 2014, the worker filed a lawsuit against the airline in the Massachusetts Superior Court for Plymouth County. Among other claims, the employee accused the airline of intentional and negligent infliction of emotional distress. According to the worker, she suffered stress, anxiety, depression, and other maladies as a result of the airline’s conduct.
The airline removed the case to federal court and filed a motion to dismiss the woman’s lawsuit. According to the District of Massachusetts, a complaint must state a claim on which relief may be granted and be plausible on its face in order to survive a motion to dismiss. The court then turned to the woman’s emotional distress claims.
According to the employer, the worker’s negligent and intentional infliction of emotional distress causes of action were both preempted by the Massachusetts Workers’ Compensation Act (“MWCA”). Because of this, the airline argued the court lacked jurisdiction to consider the claims. The court stated the MWCA prohibits an employee from bringing a claim for personal injuries that arise out of the worker’s employment against his or her employer. In addition, the court said relevant precedent states this bar applies to negligent and intentional infliction of emotional distress causes of action.
The court then disagreed with the worker’s assertion that her claims did not arise out of her employment because the alleged injuries were inflicted while she was on leave. The court stated the alleged acts occurred due to the worker’s employment relationship with the airline. In addition, the court found that the woman was an airline employee at all relevant times. Since the worker suffered her alleged injuries in the context of an employment relationship, the District of Massachusetts held that her negligent and intentional infliction of emotional distress claims were barred by the MWCA and dismissed her case.
If you suffered a serious injury at a Boston workplace, you should discuss your rights with the hardworking workers’ compensation lawyers at Kantrovitz & Associates, P.C. Our knowledgeable attorneys are here to help you recover the benefits you may be entitled to following a work-related accident. To speak with a caring Massachusetts workers’ compensation advocate about your case, give Kantrovitz & Associates, P.C. a call today at 800-367-0871 or contact us online.
Branyan v. Southwest Airlines Co., Dist. Court, D. Massachusetts 2015