Case of Lettich

530 N.E.2d 159, 403 Mass. 389 (1988)

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Case of Lettich

Massachusetts Supreme Judicial Court
530 N.E.2d 159, 403 Mass. 389 (1988)

Facts

In 1965 Robert Lettich (plaintiff) was employed by a patent-law firm. In June 1970, Lettich began to have chest pain. Lettich was out of work for three months after developing angina pectoris. In January 1974, Lettich was admitted to Salem Hospital for an angina attack. In June 1974, Lettich was diagnosed with coronary-artery disease. In the following years, the attacks were more frequent. In 1980 Lettich did not receive a raise, but his other nonlegal coworkers did. Lettich was not allowed to chair partnership meetings, although he had in the past. On March 18, 1982, Lettich suffered a severe angina attack and did not return to work. On February 8, 1983, Lettich filed a workers’-compensation claim against his employer and its insurer (defendants), arguing work-related stress exacerbated his preexisting heart disease. A single member of the reviewing board of the Department of Industrial Accidents denied the claim after a conference. A different board member then ruled in favor of Lettich based on the evidence. Specifically, Dr. Alan Balsam issued a report finding a causal connection between Lettich’s work-related stress and heart disease. However, Dr. Balsam did not treat Lettich. The deposition of Lettich’s attending physician, Dr. Maximilliaan Kaulbach, was admitted, in addition to medical records. Dr. Kaulbach testified that there was no worsening of Lettich’s condition several years prior to ending his employment. Dr. Kaulbach testified that there was a natural progression of an underlying disease unrelated to Lettich’s work. The full reviewing board reversed the member’s decision and vacated the award, finding that Lettich failed to provide sufficient evidence to establish that his condition was caused by work-related stress. Lettich appealed to the Massachusetts Appeals Court, arguing that the board acted beyond its authority in overturning the single member’s decision. The Massachusetts Supreme Judicial Court took the case on its own initiative.

Rule of Law

Issue

Holding and Reasoning (O’Connor, J.)

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