Daniel Wright's Case

Summary

The Massachusetts Supreme Judicial Court held that a workers' compensation insurer could not be required to reimburse an employee for medical marijuana expenses. The court relied on the Massachusetts medical marijuana law's provision stating that nothing in the law requires a health insurance provider or government agency to reimburse such expenses, concluding that this specific provision controls over the general workers' compensation requirement to pay reasonable and necessary medical expenses. The court affirmed the denial of Daniel Wright's reimbursement claim.

Holdings

1. A workers' compensation insurer may not be compelled to reimburse a claimant for medical marijuana expenses because the Massachusetts medical marijuana act expressly provides that nothing in the act requires a health insurance provider to reimburse such expenses.
2. Workers' compensation insurers are health insurance providers for purposes of the medical marijuana act's reimbursement limitation because workers' compensation insurance provides medical expenses and associated health care payments.
3. The Workers' Compensation Trust Fund may not be required to reimburse medical marijuana expenses because it is a government entity within the medical marijuana act's prohibition on requiring a government agency or authority to reimburse such expenses.
4. The court did not decide whether federal law independently preempts the Massachusetts medical marijuana scheme or whether reimbursement would violate the Controlled Substances Act because the state reimbursement limitation resolved the case.

Questions Presented

1. Whether a workers' compensation insurer may be compelled to reimburse an employee for medical marijuana expenses under the general workers' compensation provisions requiring payment of reasonable and necessary medical expenses.
2. Whether the Massachusetts medical marijuana act's provision stating that it does not require a health insurance provider or government agency or authority to reimburse medical marijuana expenses applies to workers' compensation insurers and the Workers' Compensation Trust Fund.
3. Whether federal illegality or federal preemption independently bars the requested reimbursement.

Disposition

affirmed