Suicide not employer's fault

In 1988, Santo J. Alba was hired by Raytheon Co. as a sheetmetal foreman in its Bedford, Mass., plant. Over the years, his responsibilities increased, requiring him to work longer hours. In March 1994, Alba was hospitalized due to severe depression and was diagnosed with bipolar disorder. Alba told his psychiatrists he was under pressure at work, and they recommended he reduce his hours. When Alba returned to work in April 1994, he was assured his job was secure and he would not be required to work more than 40 hr/week.

For the next 15 months, Alba worked no more than 40 hr/week. On May 15, 1995, he was temporarily reassigned to a different area of Raytheon, and Alba did not object. Later that day, he was found dead in a Raytheon shop, the victim of a self-inflicted head injury.

Alba's widow, Delores, filed a claim for workers'-compensation benefits with the Massachusetts Department of Industrial Accidents. After a six-day hearing, the administrative judge found that Alba had not sought any special accommodations from his employer when he returned to work in April 1994, and there was no evidence that Alba's employment with Raytheon was the predominant contributing cause of his suicide. Based on this, the judge concluded that Alba's death did not arise out of and in the course of his employment, and Mrs. Alba was not entitled to benefits.

Mrs. Alba then filed a civil lawsuit in Superior Court against Raytheon, arguing the company had discriminated against her husband because of his mental illness, in violation of Massachusetts law.

Raytheon asked the court to grant summary judgment for it before trial, arguing it had provided the only accommodation requested by Alba — that he work no more than 40 hr/week. The company also argued that the ruling by the administrative judge in the workers'comp case barred Mrs. Alba from trying to prove that Alba suffered any harm arising from his employment. The Superior Court judge agreed that Mrs. Alba was estopped from pursuing her discrimination lawsuit by the findings of the administrative judge in the workers'-comp case. Mrs. Alba appealed that decision, and lost. The Massachusetts Supreme Judicial Court held that the administrative judge's conclusion that Raytheon had not refused to make reasonable accommodations for Alba was binding on her discrimination lawsuit, and the trial judge was correct in rejecting that lawsuit.