Modica v. Sheriff of Suffolk County, 74 N.E.3d 1233

George Modica, a Suffolk County correction officer, developed sinus tachycardia with light-headedness and dyspnea after breaking up inmate fights in 2010.
Two independent physicians found the symptoms were a physiological stress response, not structural heart disease, and not caused by or causing physical damage.
Modica settled his workers' compensation claim acknowledging a physiological response to the altercations.
He then sought supplemental compensation under G. L. c. 126, § 18A (and G. L. c. 30, § 58), which pay the wage difference for employees who receive "bodily injuries" from prisoner violence.
The sheriff/Commonwealth denied the § 18A/§ 58 claims; the Superior Court granted summary judgment to defendants, holding the tachycardia was a functional change without physical damage and thus not a "bodily injury."
The Supreme Judicial Court reviewed de novo whether "bodily injury" in § 18A includes Modica’s functional cardiac condition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether "bodily injury" in G. L. c. 126, § 18A covers Modica's sinus tachycardia	Modica: the condition is an injury from inmate violence and may be long‑lasting, so § 18A should cover it	Defendants: "bodily injury" means physical damage or impairment; Modica’s condition is a functional/stress response without structural physical injury	The Court held "bodily injury" means physical injury/impairment; tachycardia without structural damage is not covered
Whether the statutory term should be broadly construed to extend special protection	Modica: § 18A should be construed broadly to effectuate the statute’s remedial purpose for correction officers	Defendants: statutory language deliberately uses the narrower term "bodily injury" (not "personal injury"), so interpretation must be confined to physical injury	The Court declined broad construction; legislative choice of "bodily" rather than "personal" indicates a narrower meaning

Massachusetts Insurers Insolvency Fund v. Berkshire Bank, 475 Mass. 839 (2016) (summary judgment / de novo review framework)
Commonwealth v. Bell, 442 Mass. 118 (2004) (use of ordinary meanings where statute is silent)
Commonwealth v. Zone Book, Inc., 372 Mass. 366 (1977) (statutory interpretation principles)
Allstate Ins. Co. v. Diamant, 401 Mass. 654 (1988) ("bodily injury" construed to mean physical injuries and their consequences)
Conroy v. Boston, 392 Mass. 216 (1984) (statutory construction in § 18A context—act of violence interpretation)
Bisazza's Case, 452 Mass. 593 (2008) (distinguishing "personal injury" under workers' compensation)
Polaroid Corp. v. Commissioner of Revenue, 393 Mass. 490 (1984) (words construed in context of statutory scheme)