Alexander Santiago Rosa v. Affordable Interior Systems, Inc.

CourtMassachusetts Appeals Court
DecidedAugust 27, 2025
Docket24-P-0540
StatusUnpublished

This text of Alexander Santiago Rosa v. Affordable Interior Systems, Inc. (Alexander Santiago Rosa v. Affordable Interior Systems, Inc.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alexander Santiago Rosa v. Affordable Interior Systems, Inc., (Mass. Ct. App. 2025).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

24-P-540

ALEXANDER SANTIAGO ROSA

vs.

AFFORDABLE INTERIOR SYSTEMS, INC.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

On November 24, 2018, the plaintiff, Alexander Santiago

Rosa, was injured while working as a temporary employee for the

defendant, Affordable Interior Systems, Inc., on assignment from

Randstad North America, Inc. (Randstad), a staffing firm

employed by the defendant. On March 6, 2020, the plaintiff

filed a complaint in Superior Court alleging that he was injured

due to the defendant's negligence, gross negligence, and

reckless, willful, and wanton conduct. On July 6, 2022, the

defendant moved for summary judgment asserting, inter alia, that

the exclusivity provisions of the workers' compensation act

(act), set forth in G. L. c. 152, §§ 23-24, render it immune from tort liability.1 A judge of the Superior Court agreed, and,

on May 15, 2023, granted the defendant's motion and entered

judgment in favor of the defendant. The plaintiff subsequently

filed a motion for reconsideration which was denied on July 23,

2023. This appeal followed. We affirm.

Background. Randstad entered into a staffing agreement

with the defendant which provided that Randstad was responsible

for interviewing, hiring, assigning, and paying employees, while

the defendant was responsible, inter alia, for supervising

employees' day-to-day work, safeguarding the premises, and

providing safety training. At all relevant times, Randstad

maintained a workers' compensation and employers' liability

insurance policy with Ace American Insurance Company. The

policy contains an "alternate employer endorsement" that

explains when the policy applies to alternate employers. The

alternate employer endorsement does not name specific alternate

employers but references an amendatory endorsement. The

amendatory endorsement defines an alternate employer as "[a]ll

On April 15, 2020, the defendant initially filed on a 1

motion to dismiss which was allowed by a judge of the Superior Court on August 4, 2020. However, this court reversed the judgment, concluding that the judge erroneously considered evidence outside of the complaint without first converting the defendant's motion to dismiss to one for summary judgment. See Rosa v. Affordable Interior Systems, Inc., 100 Mass. App. Ct. 1128 (2022). On remand, this summary judgment action then followed.

2 clients for which the insured has agreed to provide workers[']

compensation insurance and employers['] liability insurance

under a written contract or agreement, except that no client is

an alternate employer for claims arising out of the alternate

employer's negligence unless that applicable contract

specifically denotes such an obligation." The motion judge

concluded that the staffing agreement between Randstad and the

defendant was such a "written contract or agreement"

contemplated by the amendatory endorsement, and therefore the

defendant qualified as an alternate employer for purposes of the

endorsement. As a result, the judge found that the defendant

satisfied the requirements for immunity, as set forth in our

decision in Lang v. Edward J. Lamothe Co., 20 Mass. App. Ct.

231, 232 (1985).

On appeal, the plaintiff argues that because the defendant

was not specifically named in the amendatory endorsement, the

defendant does not qualify as an "insured person" pursuant to

our decision in Lang, supra, and is therefore not entitled to

immunity under the act. The plaintiff also asserts that a valid

waiver of claims is a prerequisite for immunity, and that the

defendant failed to obtain such a waiver here. We address the

plaintiff's arguments in turn.

Discussion. 1. Standard of review. "[W]e review the

motion judge's grant of summary judgment de novo." Molina v.

3 State Garden, Inc., 88 Mass. App. Ct. 173, 177 (2015). "The

standard of review of a grant of summary judgment is whether,

viewing the evidence in the light most favorable to the

nonmoving party, all material facts have been established and

the moving party is entitled to judgment as a matter of law

(citations omitted)." Id.

2. Immunity under the workers' compensation act. The act

"provides the exclusive remedy for claims brought by an injured

employee against an employer." Molina, 88 Mass. App. Ct. at

178. "The [A]ct was designed to replace tort actions, by

providing a uniform, statutory remedy for injured workers, in

contrast to a piecemeal, tort-based system" (citation omitted).

Id. Although the "exclusivity provisions are the 'cornerstone'

of the Act . . . . [s]ection 15 of the Act leaves open the

possibility that, notwithstanding receipt of workers'

compensation benefits from the employer, an injured employee may

bring tort actions against other entities." Id. at 178-179.

"[F]or an employer to be immune under [the act] from an

employee's common law action, that employer must satisfy a two-

part test: '(1) the employer must be an insured person liable

for the payment of compensation, and (2) the employer must be

4 the direct employer[2] of the employee'" (the Lang test). Lang,

20 Mass. App. Ct. at 232.

Here, it is undisputed that the defendant was the

plaintiff's direct employer and thus satisfies part two of the

Lang test. Therefore, the question is whether the defendant

satisfies part one of the test, which asks "whether the employer

is insured and liable for workers' compensation benefits owed

the employee." Molina, 88 Mass. App. Ct. at 179. In cases such

as the one here, "where there is both a general and a special

employer, § 18 of the Act comes into play." Id. The last

paragraph of G. L. c. 152, § 18 provides:

"In any case where there shall exist with respect to an employee a general employer and a special employer relationship, as between the general employer and the special employer, the liability for the payment of compensation for the injury shall be borne by the general employer or its insurer, and the special employer or its insurer shall be liable for such payment if the parties have so agreed or if the general employer shall not be an insured or insured person under this chapter."

"Thus, if a special employer is also the injured employee's

direct employer (thus satisfying part two of the test), and the

general and special employer have agreed that the latter shall

be liable for carrying workers' compensation insurance and

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Related

Lang v. Edward J. Lamothe Co.
479 N.E.2d 208 (Massachusetts Appeals Court, 1985)
Molina v. State Garden, Inc.
37 N.E.3d 39 (Massachusetts Appeals Court, 2015)
Fleming v. Shaheen Bros.
881 N.E.2d 1143 (Massachusetts Appeals Court, 2008)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)

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