Summary
The Massachusetts Supreme Judicial Court held that an employee who suffered a physically disabling heart attack caused by emotional stress upon learning that her position would be eliminated sustained a personal injury within the meaning of the accidental disability retirement statute. The court concluded that the injury was sustained during the performance of her duties because she was responding to her supervisor's direction to discuss her employment status, even though the heart attack occurred after she left work. The court affirmed the Contributory Retirement Appeal Board's award of accidental disability retirement benefits, which belonged to the employee's estate after her death.
Topics
Practice areas
Questions Presented
- Whether a physical heart attack caused by emotional stress from notification of a bona fide personnel action constitutes a qualifying personal injury under G. L. c. 32, § 7 (1).
- Whether an injury occurring after an employee leaves the workplace was sustained as a result of, and while in the performance of, employment duties when the injury was caused by a conversation with the employee's supervisor during the workday.
- Whether CRAB's decision awarding accidental disability retirement benefits was legally erroneous or unsupported by substantial evidence under G. L. c. 30A, § 14.
Holdings
- A physical heart attack caused by emotional stress from notification of an impending termination qualifies as a personal injury for purposes of accidental disability retirement benefits, even though the emotional stress arose from a bona fide personnel action.
- An injury occurring after the employee leaves work may nevertheless be sustained during the performance of employment duties when it is caused by emotional stress incurred while the employee responds to a supervisor's direction during the workday.
- CRAB's determination that Cole qualified for accidental disability retirement benefits was supported by the record and was not legally erroneous.
Key quotations
“We conclude that this personnel action exception does not bar the employee here from receiving benefits because the exception applies only to emotional or mental disabilities and the employee’s heart attack, although caused by the emotional stress of hearing from her supervisor of her forthcoming termination, resulted in a physical disability.” (453 Mass. at 290)
“Clearly her compliance with the supervisor’s direction to speak with him about this subject qualifies as being actively engaged in the performance of her duties.” (453 Mass. at 291)
Factual background
Claire Cole, a Salem public works administrative assistant, was told by her supervisor during the workday that her position would be eliminated. She became distressed, left work, and suffered an acute myocardial infarction approximately one hour later. Medical findings established that the heart attack was caused in part by emotional stress from learning of the impending job loss and resulted in a permanent physical disability preventing her return to work.
Procedural history
Cole applied for accidental disability retirement benefits after suffering a heart attack shortly after being told that her employment position would be eliminated. The Salem retirement board approved her application twice, but PERAC reversed and remanded both times; the board later denied the application, and DALA and CRAB initially affirmed the denial. After a Superior Court remand for further medical findings, DALA again affirmed the denial, but CRAB reversed and awarded benefits. The Superior Court affirmed CRAB, and the Retirement Board appealed.