Robidoux v. Muholland
642 F.3d 20
1st Cir.2011Background
- Robidoux, MA resident, worked on Rhode Island project for James Construction via MA labor agency Labor Systems.
- Labor Systems dispatched Robidoux from MA; supervision by Muholland in RI.
- Robidoux received MA workers’ compensation benefits after a Rhode Island injury.
- Massachusetts administrative judge awarded MA benefits and ordered credit to payors; RI benefits were paid temporarily.
- Diversity suit in MA federal court alleging negligence; district court held RI Act immunity applied; MA choice governs; court now reverses and remands.
- Injury occurred in RI; interplay of MA and RI workers’ compensation regimes central to immunity issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which state's workers’ compensation immunity governs? | Robidoux contends RI Act immunity controls. | Defendants argue RI Act immunity blocks claims. | Massachusetts Act governs; not barred by MA immunity. |
| Does the MA Act immunize the defendants as to Robidoux’s suit? | MA immunity extends to special and co-employers? | Immunity applies only if MA criteria met. | MA Act immunity does not bar the claims. |
| Is James Construction an 'insured person' liable for compensation under MA Act? | James Construction bears responsibility for compensation. | Labor Systems provides the workers’ comp; James is not insured. | James Construction not an insured person liable for compensation. |
| Does Muholland have co-employee immunity under MA Act? | Co-employee immunity exists. | Immunity requires MA prerequisites not satisfied. | No co-employee immunity here. |
| Under MA choice-of-law, which state's law governs immunity? | Rhode Island law should apply due to contacts. | Massachusetts has greater interest; MA law governs. | Massachusetts choice-of-law principles apply; MA law governs immunity. |
Key Cases Cited
- Cosme v. Whitin Mach. Works, Inc., 417 Mass. 643 (Mass. 1994) (functional approach; §6 factors; interest analysis)
- Barrett v. Rodgers, 408 Mass. 614 (Mass. 1990) (Mass. Act bars employee recovery from employer but allows third-party actions)
- Roberts v. Delta Air Lines, Inc., 599 F.3d 73 (1st Cir. 2010) (special-employer immunity analysis under MA Act)
- Fleming v. Shaheen Bros., Inc., 71 Mass.App.Ct. 223 (Mass. 2008) (immunity prerequisites for MA Act; insured liable for compensation)
- Searcy v. Paul, 20 Mass.App.Ct. 134 (Mass. 1985) (common-law action posture and MA Act relations)