Urrutia v. Interstate Brands InternationalAnnotate this Case
Me. Rev. Stat. 39-A, 221 entitles an employer to a credit for workers’ compensation benefits previously paid for the same liability period when the employee was also receiving Social Security retirement benefits.
Plaintiff was paid total incapacity workers’ compensation benefits by his employer, Interstate Brands International, after he sustained injuries in an initial workplace accident. For three years, Plaintiff collected Social Security retirement benefits while receiving the full amount of the workers’ compensation benefits. When Interstate learned that Plaintiff was receiving Social Security benefits, it sought a credit against the ongoing incapacity payments pursuant to section 221. A hearing officer determined that Interstate was entitled to a credit of nearly $25,000. The Workers’ Compensation Appellate Division vacated the decree, concluding that section 221 does not allow a reduction based on incapacity overpayments made in the past. The Supreme Judicial Court vacated the Appellate Division’s decision, holding that Interstate was entitled to a credit for incapacity benefit overpayments made to Plaintiff during the same period when he received Social Security retirement benefits.