## Facts

- Blanche Thibeault worked as an attendant nurse at a Massachusetts state institution with separate infirmaries.
- Thibeault had preexisting heart symptoms and, after returning from an absence in May 1958, was assigned to the girls’ infirmary and told to do only light work.
- The Industrial Accident Board’s single member found that Thibeault did heavy lifting at work that culminated in a heart attack on or about August 31, 1958.
- The single member also found additional heart attacks on January 4, 1959 and June 2, 1959, and total incapacity from September 1 to December 2, 1958 and from January 5 to November 23, 1959.
- After episodes, Thibeault or her daughter notified institutional personnel that she was “sick,” and supervisors knew she became ill while working on certain dates, but the record did not clearly show they knew she had suffered a work-connected “injury” for which compensation was claimed.
- The single member did not find the fact or date of any written notice of injury or written claim, but concluded the Commonwealth (a self-insured employer) was not prejudiced because persons in superintendence had “full knowledge of the claimant’s condition” and she received medical care.
- The reviewing board adopted the single member’s findings; the Superior Court entered a decree enforcing the award; the Commonwealth appealed.

## Issues

1. Whether failure to give statutory written notice of injury could be excused because the employer had “knowledge of the injury” or because the insurer was “not prejudiced” by the lack of notice.
2. Whether failure to file a timely written claim could be excused because the insurer was “not prejudiced by the delay.”
3. Whether the board’s findings and record were sufficient to support excusing noncompliance with the notice and claim requirements.

## Decision

- The Supreme Judicial Court reversed the Superior Court decree enforcing the award and remanded for further proceedings.
- The court held the board’s findings were too generalized to permit determination whether statutory notice and claim requirements were satisfied or properly excused.
- The court ruled that “knowledge of the claimant’s condition” (e.g., that she was ill or had heart trouble) did not necessarily establish “knowledge of the injury” as required to excuse lack of written notice.
- The court held the board’s “no prejudice” conclusion lacked specific factual support showing the employer’s ability to investigate or defend the claim was not harmed by missing notice or delayed claim.

## Legal Principles

- The employee bears the burden to prove statutory grounds excusing noncompliance with written notice and claim requirements, including employer knowledge of the injury or lack of prejudice from missing notice or delayed claim.
- “Knowledge of the injury” requires awareness of the occurrence of the compensable, work-connected injury for which compensation is sought, sufficient to allow timely investigation; knowledge of illness alone is insufficient.
- A finding of “no prejudice” must rest on specific facts demonstrating the omission or delay did not impair investigation or defense; providing medical care or general supervisory awareness does not, by itself, establish lack of prejudice.
- Administrative findings must be sufficiently specific and supported by evidence to allow judicial review of statutory compliance and application of exceptions.

## Conclusion

The court set aside the compensation award because the board failed to make clear, reviewable findings on whether written notice and claim were timely, and, if not, whether the Commonwealth had the required knowledge of a work-related injury or was not prejudiced by the lack of notice or delayed claim.


Thibeault's Case, 341 Mass. 647, 171 N.E.2d 151 (Mass. 1961)