Facts
- William Murphy worked for A.A. Busch & Co. of Massachusetts, Inc. and suffered a myocardial infarction in August 1991.
- He filed a workers’ compensation claim alleging his heart condition arose out of employment.
- William Murphy died of a heart attack on March 19, 1992, while the claim was pending.
- Jean Murphy, his widow, sought to amend the claim to add herself and pursue survivor benefits under G.L. c. 152, § 31.
- After an adverse conference order under G.L. c. 152, § 10A (July 17, 1992), Murphy sought to appeal for a full evidentiary hearing involving disputed medical issues.
- Under G.L. c. 152, § 11A (as amended in 1991), a claimant represented by counsel appealing a conference order involving medical issues had to pay a fee equal to the Commonwealth’s average weekly wage to fund an impartial medical examination; pro se claimants were exempt.
- Murphy wished to proceed with counsel but asserted she could not afford the § 11A fee and challenged the fee’s constitutionality.
Issues
- Whether G.L. c. 152, § 11A violates equal protection by requiring a substantial medical-exam fee from claimants represented by counsel, while exempting pro se claimants.
- Whether the same fee scheme violates Massachusetts Declaration of Rights art. 11 by conditioning access to adjudication on payment by only one class of claimants.
Decision
- The Supreme Judicial Court held the challenged fee provisions unconstitutional under the Fourteenth Amendment and Massachusetts Declaration of Rights art. 11.
- The court applied rational-basis review and concluded the distinction between represented and unrepresented claimants lacked a rational relationship to a legitimate governmental purpose.
- The court declared invalid the portions of § 11A that imposed a fee only on claimants represented by counsel (and set the fee at the Commonwealth’s average weekly wage).
- The case was remanded for entry of judgment consistent with the ruling.
Legal Principles
- When a statutory classification does not involve a suspect class or fundamental right, equal protection is evaluated under rational-basis review; the classification must be rationally related to a legitimate governmental interest.
- A fee aimed at defraying the cost of an adjudicatory requirement must not arbitrarily single out one subset of similarly situated litigants without a rational justification.
- Massachusetts Declaration of Rights art. 11 protects access to the courts and related adjudicatory processes by securing a remedy “freely” and “without being obliged to purchase it”; selective financial barriers that effectively deter meaningful access may violate art. 11.
Conclusion
The court invalidated a workers’ compensation medical-examination fee imposed only on claimants represented by counsel because the classification was irrational in relation to cost-defraying goals and improperly burdened access to the administrative adjudication process under both equal protection and art. 11.