Mark Cerasoli, Employee, Hale Development, Employer, Liberty Mutual Insurance Co., Insurer

13 Mass. Workers’ Comp. Rep. 267 (1999)

From our private database of 45,900+ case briefs, written and edited by humans—never with AI.

Mark Cerasoli, Employee, Hale Development, Employer, Liberty Mutual Insurance Co., Insurer

Massachusetts Department of Industrial Accidents
13 Mass. Workers’ Comp. Rep. 267 (1999)

Facts

Mark Cerasoli (plaintiff) was employed by Hale Development (Hale) (defendant). In September 1992, Cerasoli allegedly injured his back at work while lifting a heavy bag of cement. Hale’s insurer, Liberty Mutual Insurance Company (Liberty) (defendant), voluntarily paid workers’-compensation benefits to Cerasoli until September 1993. When Liberty’s voluntary payments ended, Cerasoli filed a formal claim for benefits with the Massachusetts Department of Industrial Accidents. Liberty refused to pay Cerasoli, asserting, among other things, that witnesses and documentary evidence disputed Cerasoli’s claim that he had been injured in the course of his employment. In November 1993, following a conference between the parties, an administrative-law judge (ALJ) denied Cerasoli’s claim for benefits in a blanket order that did not make any specific findings regarding liability, causation, or any other factors. Cerasoli did not appeal the denial, but he filed a new workers’-compensation claim two years later based on the same injury Cerasoli allegedly suffered in September 1992. Cerasoli’s claim was assigned to a different ALJ from the ALJ who had denied Cerasoli’s original claim. Liberty raised a res judicata defense before the new ALJ, and the new ALJ denied Cerasoli’s claim. Cerasoli appealed. At a hearing on the appeal, the judge held that the unappealed November 1993 order denying Cerasoli’s claim bound the parties only with respect to matters that had explicitly been decided in the order. Because the order was silent on the ALJ’s grounds for decision, the judge held that the order had no preclusive effect. The judge thus issued a decision that allowed Cerasoli to litigate the merits of the workers’-compensation claim, including the issue of original liability for Cerasoli’s injury. Liberty appealed, again arguing that res judicata and issue preclusion barred any further litigation of Cerasoli’s claim.

Rule of Law

Issue

Holding and Reasoning (Smith, J.)

Dissent (McCarthy, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 734,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 734,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 45,900 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 734,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 45,900 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership