Thibeault’s Case

Blanche Thibeault (plaintiff) was employed as a nurse at a state institution (defendant). Thibeault was engaged in heavy lifting in the girls’ infirmary when she had a heart attack on or around August 31, 1958. Thibeault filed for workers’-compensation benefits for the heart attack on September 9, 1958. Thibeault also claimed that she suffered another heart attack on January 7, 1959, when lifting a tray in the boys’ infirmary. Thibeault’s daughter called someone at the institution after each heart attack to report Thibeault as sick, but she did not report the details of the attacks. The institution’s supervisor knew that Thibeault was sick, and another employee, Generoux, spoke to the supervisor with regard to the incident that occurred on or around August 31 or September 9, 1958. The supervisor had knowledge that Thibeault became sick while working on June 3, 1959, but was unaware that she had suffered a heart attack. At the hearing, Biggine, the institution’s treasurer, testified that Thibeault was examined by the institution’s physician, Dr. Quinn, in April 1959. Thibeault was also examined by Dr. Brooks in May 1959 and subsequently returned to light-duty work until she could no longer work. A member of the Industrial Accident Board (the board) found Thibeault totally incapacitated from September 1 to December 2, 1958, and from January 5 to November 23, 1959. The member found Thibeault had suffered heart attacks around August 31, 1958, January 4, 1959, and June 2, 1959. The member found that the insurer, the commonwealth (defendant), was not prejudiced on the basis that the superintendency had full knowledge of Thibeault’s condition, and the member found that she received adequate medical care following her injuries. The member awarded compensation to Thibeault. The reviewing board adopted the findings. The superior court entered a decree enforcing the board’s decision, and the commonwealth appealed, arguing that there was insufficient evidence to support a finding that the commonwealth had knowledge of the injury or that it was not prejudiced by the want of notice or delay in filing the claim.