Matthews v. Liberty Assignment Corp.Annotate this Case
Albert Matthews settled his workers’ compensation claim against his employer and others in a structured settlement approved by the Workers’ Compensation Appeals Board. Matthews obtained an award in his workers’ compensation proceeding, based on a compromise and release containing the terms of the structured settlement agreement, then obtained a court judgment based on the workers’ compensation award. In this appeal, WC challenged the denial of its motion for a qualified order approving the assignment to it of a judgment providing for structured settlement payments otherwise payable to Mathews. Consistent with federal law, the Massachusetts statute providing for approval of the transfer of payments under a structured settlement agreement requires that the court or administrative authority asked to approve the transfer expressly find that the transfer “will not contravene other applicable law.” The trial court, in determining whether to issue a qualified order for the transfer of the structured settlement payments, concluded that the transaction would contravene California law, because Labor Code section 4900 prohibits the assignment. The court concluded that the trial court properly denied WC’s motion, because the assignment of Matthews’ structured settlement payments contravened section 4900. Furthermore, the transaction contravened the order of the responsible administrative authority. The court rejected WC's arguments and affirmed the judgment.