Saharceski v. Marcure
373 Mass. 304, 1977 Mass. LEXIS 1085, 366 N.E.2d 1245 (1977)
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Rule of Law:
When determining whether an employee may sue a fellow employee in tort, the law of the state of their common employment and domicile applies, rather than the law of the state where the injury occurred, due to that jurisdiction's more significant interest in the employment relationship and the parties' reasonable expectations.
Facts:
- The plaintiff and the defendant were both residents of Massachusetts.
- Both parties were employees of Ethan Ames Manufacturing Co., Inc., a Massachusetts corporation, and had been hired in Massachusetts.
- On June 1, 1970, while acting in the course of their employment, the parties were traveling on company business in a company-owned vehicle registered in Massachusetts.
- The defendant was operating the vehicle on the Connecticut Turnpike when he negligently struck another vehicle.
- The plaintiff, a passenger, sustained injuries in the accident.
- The parties were merely passing through Connecticut and did not intend to conduct any business in that state.
- The plaintiff collected workmen's compensation benefits from the employer's Massachusetts insurance carrier.
Procedural Posture:
- The plaintiff filed a negligence action against the defendant in a Massachusetts trial court.
- At the close of evidence, the defendant's motion for a directed verdict, based on the immunity granted by the Massachusetts Workmen's Compensation Act, was denied.
- The jury returned a verdict for the plaintiff.
- Following the verdict, the trial judge granted the defendant's motion for judgment notwithstanding the verdict, thereby setting aside the jury's decision and entering judgment for the defendant.
- The plaintiff appealed the entry of judgment notwithstanding the verdict to the Supreme Judicial Court of Massachusetts.
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Issue:
Does Massachusetts law, which provides tort immunity to a fellow employee for a work-related injury covered by workers' compensation, apply to bar a suit between two Massachusetts employees when their work-related motor vehicle accident occurred in Connecticut, a state that permits such lawsuits?
Opinions:
Majority - Wilkins, J.
Yes. The substantive law of Massachusetts applies to bar recovery by the plaintiff against his fellow employee. Instead of rigidly applying the law of the place of the tort, the court looks to the jurisdiction with the more significant interest in the dispute. Here, that jurisdiction is Massachusetts, as both parties are residents, were hired there, and their employment relationship is centered there. The court's reasoning emphasized the parties' reasonable expectations, which were formed under Massachusetts' comprehensive workers' compensation scheme that explicitly has employees waive tort claims against co-workers. Applying Massachusetts law provides certainty and avoids making liability dependent on the 'fortuitous circumstance' of where an accident occurs, which the court likened to 'a sort of unknowing geographical Russian roulette.'
Analysis:
This decision represents a significant shift in Massachusetts choice-of-law jurisprudence, moving away from the traditional, rigid rule of 'lex loci delicti' (law of the place of the wrong) in certain tort contexts. It adopts a more modern, flexible approach that considers the state with the most significant relationship to the parties and the issue. The ruling establishes a strong precedent that for issues of intra-employee tort immunity, the law of the common domicile and place of employment will govern, thereby reinforcing the state's interest in its own workers' compensation system. This provides predictability for employers and employees in Massachusetts, ensuring that the rights and immunities established by the employment relationship are not subverted by crossing state lines.
