Estate of Moulton v. Puopolo

by
Stephanie Moulton was employed as a residential treatment counselor at North Suffolk Mental Health Association, Inc. when she was assaulted by DeShawn Chappell, one of the facility’s residents, causing her death. Moulton’s estate brought an action against the directors of North Suffolk, among other defendants, asserting claims for wrongful death and breach of fiduciary duty. The director defendants moved to dismiss the complaint on the grounds that (1) with respect to the wrongful death action, they were immune from suit, as Moulton’s employer, under the exclusive remedy provision of the Workers’ Compensation Act (Act); and (2) with respect to the breach of fiduciary duty claim, they owed Moulton no such duty. The superior court denied the director defendants’ motion to dismiss. The Supreme Judicial Court vacated the superior court’s judgment, holding (1) the director defendants were immune from suit under the exclusive remedy provision of the Act for the injuries Moulton sustained while acting within the course of her employment; and (2) the directors, as Moulton’s employer, owed no fiduciary duty to their employee. Remanded for an entry of judgment for the director defendants on all claims. View "Estate of Moulton v. Puopolo" on Justia Law