MICHAEL MEEHAN v. LAZER SPOT, INC., & Another.
23-P-180
Mass. App. Ct.Sep 11, 2024Background
- Michael Meehan, employed as a yard switcher by Lazer Spot, Inc., was injured after his work shift when struck by a company vehicle operated by a coemployee, Chailyn Ortiz, in a parking lot designated for employee use.
- The accident occurred as Meehan walked from the office trailer, where he clocked out, toward his car in the lot adjacent to the workplace, all within the area Lazer Spot and its employees were permitted to use.
- Meehan filed a negligence lawsuit against Lazer Spot and Ortiz, alleging he was not within the course of his employment at the time of injury.
- The trial court granted summary judgment for the defendants, holding workers’ compensation was Meehan’s exclusive remedy.
- Meehan appealed, arguing his injury was not covered by the exclusivity provision of the Massachusetts Workers' Compensation Act.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Exclusivity of workers’ comp | Meehan not in course of employment post-shift | Plaintiff was departing via employer’s premises | Exclusivity provision applies; claim barred |
| Scope of employer’s premises | Injury was in area controlled by Home Depot, not Lazer Spot | Area was designated for Lazer Spot employees; right of use assigns liability | Right of use—control not dispositive if employment connects risk |
| Post-shift injuries in parking lot | Departure to personal vehicle not work-related | Walking to car in employer lot is incidental to employment | Injury arose in course of employment; covered by workers’ compensation |
| Written reservation of common-law claims | Not addressed directly | No written notice reserving common law rights | No notice given, so exclusive remedy statute bars negligence claim |
Key Cases Cited
- Molina v. State Garden, Inc., 88 Mass. App. Ct. 173 (exclusive remedy under workers’ compensation for workplace injuries)
- Mendes v. Tin Kee Ng, 400 Mass. 131 (employee injured by coworker in course of employment barred from suit)
- Mannering’s Case, 290 Mass. 517 (compensability for injuries departing employer’s premises on employer’s passageway)
- Baran’s Case, 336 Mass. 342 (material inquiry: whether employment exposed employee to injury risk)
- Sundine’s Case, 218 Mass. 1 (compensability even when employer does not control precise location if right of access is established)
- Zapponi v. Central Constr. Co., 334 Mass. 146 (risk of injury crossing employer’s premises covered by act)