Massachusetts Appeals Court Denies Employee’s Psychiatric Workers’ Compensation Claim

The Massachusetts Appeals Court recently reached a decision in the case of Litchfield’s Case, 86 Mass. App. Ct. 216 (2014), which is instructive on the matter of workers’ compensation awards for psychological complications arising out of work-related injuries.

In the case, Robert M. Litchfield had been working as a heavy equipment mechanic for his employer from 1984 until he suffered a serious industrial injury to his elbow and shoulder. Due to his pain and inability to work, which were a direct result of the physical injuries he suffered in the incident, as a result of his limitations, he developed psychiatric conditions, including anxiety and depression.

The administrative judge who initially heard Litchfield’s workers’ compensation claim for loss of psychiatric function denied his claim, finding that the benefits for loss of psychiatric function were not available to him. The reviewing board affirmed the decision, which Litchfield appealed.

Litchfield had received compensation for his injuries under the workers’ compensation system, which had included benefits for partial incapacity, temporary total capacity, and adjustments for claims related to the loss of function of his shoulder. He was eventually awarded permanent and total damages for his shoulder and elbow injuries.

Massachusetts allows for recovery in cases of mental conditions arising from industrial accidents. Therefore, Litchfield attempted to argue that the language in the relevant diagnostic guide that the Department of Industrial Accidents refers to should entitle him to recovery on the basis of his psychiatric loss of function. However, in denying his claim, the board interpreted the language within the guide to mean that, in order to be entitled to the additional compensation for psychiatric injuries, the psychiatric injury must have been caused by the industrial accident itself. Here, however, the resulting psychiatric injuries were caused as a result of the physical injuries, and therefore they were not independently compensable.

The relevant guide that the board referenced in making its determination states that:

“Under most circumstances, however, [the] impairment rating for mental health disorders related to the stressors that often accompany a chronic, disabling musculoskeletal disorder, is captured within the rating for the musculoskeletal disorder itself.”

Therefore, the Appeals Court agreed with the lower court’s decision, finding that the rating for his physical injuries was the full extent of the compensable injury, since the psychiatric injuries were tied to those injuries, rather than arising directly as a result of the accident. Thus, the decision was affirmed.

If you become injured at work, you’ll want to make sure that you’re represented by a workers’ compensation lawyer. The experienced Massachusetts workers’ compensation lawyers at Pulgini & Norton offer comprehensive guidance and representation in these matters. We will assist you throughout the entire workers’ compensation claim process. Call our office today at (781) 843-2200, or you can contact us online in order to schedule an initial consultation.

More Blog Posts:

Appeals Court of Massachusetts Upholds Decision Based on Opinion Independent Medical Examiner, Massachusetts Workers’ Compensation Lawyer Blog, published March 4, 2015

Massachusetts Court of Appeals Discontinues Workers’ Compensation in Decades-Old Case, Massachusetts Workers’ Compensation Lawyer Blog, published February 25, 2015

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