Court Finds Fatal Accident Occurred in the Performance of Job Duties

In Matthew Combra v. Contributory Retirement Appeal Board, the Massachusetts Superior Court held that the family of a deceased state employee was entitled to accidental death benefits because the employee was performing work duties at the time of a fatal car accident.

The case arose after Deborah Combra, a procurement specialist for the Massachusetts Department of Mental Health, attended a work meeting in Westborough with colleagues from the agency. After the meeting concluded, several attendees went to lunch, during which they continued discussing work-related issues that had not been fully addressed during the formal meeting. Although attendance at the lunch was not mandatory, the group spent time discussing work matters at the restaurant and in the parking lot before departing. Deborah and a coworker then drove back toward their Brockton office to continue working. During that return trip, Deborah was involved in a motor vehicle accident that resulted in her death.

Deborah’s family sought accidental death benefits under G.L. c. 32, § 9. An administrative magistrate with the Division of Administrative Law Appeals initially concluded that the death qualified for benefits because Deborah was traveling between two locations where she had employment obligations, namely, the work-related lunch discussion and her office. However, the Contributory Retirement Appeal Board reversed that decision, reasoning that the lunch gathering was informal, not scheduled in advance, not required by the employer, and therefore not part of Deborah’s official work duties.

On judicial review under G.L. c. 30A, § 14, the Superior Court disagreed with CRAB and reinstated the entitlement to benefits. The court emphasized that the undisputed facts showed that Deborah was participating in ongoing work discussions at lunch and immediately before leaving the restaurant. Because she was traveling from one place where she had a work obligation (the continuation of the meeting at the restaurant) to another such place (her office in Brockton), her fatal accident occurred while she was in the performance of her duties within the meaning of the retirement statute. The court further noted that the statute does not require that work activities be formally scheduled, mandatory, or urgent in order to qualify as employment duties.

Accordingly, the court allowed Matthew Combra’s motion for judgment on the pleadings and denied CRAB’s cross-motion, concluding that the administrative record established entitlement to accidental death benefits as a matter of law.