Maine Revised Statutes

Me. Rev. Stat. tit. 39, § 51-B (2026)

Early-pay system

✓ current as of May 2026
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(REPEALED)
SECTION HISTORY
PL 1983, c. 479, §7 (NEW). PL 1983, c. 682, §§1-6 (AMD). PL 1985, c. 372, §§A9,A10 (AMD). PL 1985, c. 729, §1 (AMD). PL 1987, c. 559, §§B17,B18 (AMD). PL 1987, c. 560, §§2,3 (AMD). PL 1989, c. 256, §§1-3 (AMD). PL 1989, c. 502, §D22 (AMD). PL 1991, c. 615, §§A25,C3 (AMD). PL 1991, c. 885, §A7 (RP). PL 1991, c. 885, §§A9-11 (AFF).
Notes of Decisions
Cited in 23 cases, 1989–2012 · leading case: Wentworth v. Manpower Temp. Servs., 589 A.2d 934 (Me. 1991).
Wentworth v. Manpower Temp. Servs., 589 A.2d 934 (Me. 1991). · cites it 9× “See 39 M.R.S.A. § 51-B (1989 & Supp.1990). In April 1987, after a hearing on Wentworth’s petition for award of compensation, the commission ordered Manpower to make the retroactive payments it owed to Wentworth for her periods of total and partial incapacity since January 1985…”
Bridgeman v. S.D. Warren Co., 2005 ME 38 (Me. 2005). · cites it 6× “1989) (codified as amended at 39 M.R.S.A. § 51-B(5), (7) (Supp.1989), repealed by P.”
Stickles v. United Parcel Serv., 554 A.2d 1176 (Me. 1989). · cites it 5× “39 M.R.S.A. § 51-B (Pamph.1988). We conclude that, by failing to file a notice of controversy within 44 days from the time an employee tells an employer that lost work time is caused by a work-related injury, the employer accepts compensability of the injury at the level of the…”
Tompkins v. Wade & Searway Constr. Corp., 612 A.2d 874 (Me. 1992). · cites it 2× “See 39 M.R.S.A. §§ 51-B(5), 51-B(7). Receipt of such payments does not constitute an acceptance by the employee of the nature and scope of an employer’s liability or of the amount or duration of the compensation.”
Marsella v. Bath Iron Works Corp., 585 A.2d 802 (Me. 1991). · cites it 4× “39 M.R.S.A. § 51-B(3) (1989). The employer must then begin making compensation payments unless he files a notice of controversy with the Commission within that time.”
Doucette v. Hallsmith/Sysco Food Servs., Inc., 2011 ME 68 (Me. 2011). · cites it 2× “See 39 M.R.S.A. § 51-B(1), (7) (1989), repealed by P.”
Est. of Joyce v. Com. Welding Co., 55 A.3d 411 (Me. 2012). “Section 205 was preceded by the controversial “early pay system,” adopted in the 1980s, whereby the failure of an employer to file a notice of controversy within rigid statutory time frames created a “compensation payment scheme” in which the employer was deemed to have accepted…”
LaRochelle v. Crest Shoe Co., 655 A.2d 1245 (Me. 1995). · cites it 2× “In separate decrees, the Commission awarded LaRochelle 50% partial incapacity benefits for the 1985 injury, and 100% benefits for the 1986 injury, based on Hanover's failure to timely controvert the claim, pursuant to 39 M.R.S.A. § 51-B (1989). Both insurers filed timely motions…”
Rowe v. Chapman Trucking, 629 A.2d 1224 (Me. 1993). · cites it 2× “39 M.R.S.A. § 51-B (1989 & Supp.1992). Five months later, on January 10, 1989, the employer made an offer in writing to the employee to reduce the employee's benefits to a level of 70% incapacity.”
Croteau-Robinson v. Merrill Trust/Fleet Bank, 669 A.2d 763 (Me. 1996). · cites it 5× “The shuttle-bus itself was nothing more than an adjunct of the parking lot, and should not be accorded immunity as a "rideshare program.”
Carroll v. Gates Formed Fibre Prods., 663 A.2d 23 (Me. 1995). · cites it 3× “39 M.R.S.A. § 51-B (1989). 1 The Commissioner found that, although the employer had notice of the injury, the employer had no notice or knowledge of an event that constituted an obligation to pay benefits.”
Wallace v. Warren, 640 A.2d 203 (Me. 1994). · cites it 2× “Warren’s in-house medical department constituted a payment of medical expenses, aids, or other services pursuant to 39 M.R.S.A. § 51-B (1989), repealed by P.”
— Me. Rev. Stat. tit. 39, § 51-B(1) — 2 cases
Doucette v. Hallsmith/Sysco Food Servs., Inc., 2011 ME 68 (Me. 2011). “See 39 M.R.S.A. § 51-B(1), (7) (1989), repealed by P.”
Rutter v. Allstate Auto. Ins., 655 A.2d 1258 (Me. 1995).
— Me. Rev. Stat. tit. 39, § 51-B(3) — 6 cases
Stickles v. United Parcel Serv., 554 A.2d 1176 (Me. 1989). “39 M.R.S.A. § 51-B (Pamph.1988). We conclude that, by failing to file a notice of controversy within 44 days from the time an employee tells an employer that lost work time is caused by a work-related injury, the employer accepts compensability of the injury at the level of the…”
Marsella v. Bath Iron Works Corp., 585 A.2d 802 (Me. 1991). “39 M.R.S.A. § 51-B(3) (1989). The employer must then begin making compensation payments unless he files a notice of controversy with the Commission within that time.”
Wentworth v. Manpower Temp. Servs., 589 A.2d 934 (Me. 1991). “See 39 M.R.S.A. § 51-B (1989 & Supp.1990). In April 1987, after a hearing on Wentworth’s petition for award of compensation, the commission ordered Manpower to make the retroactive payments it owed to Wentworth for her periods of total and partial incapacity since January 1985…”
Carroll v. Gates Formed Fibre Prods., 663 A.2d 23 (Me. 1995). “39 M.R.S.A. § 51-B (1989). 1 The Commissioner found that, although the employer had notice of the injury, the employer had no notice or knowledge of an event that constituted an obligation to pay benefits.”
Palmer v. Bath Iron Works Corp., 559 A.2d 340 (Me. 1989).
— Me. Rev. Stat. tit. 39, § 51-B(4) — 2 cases
Palmer v. Bath Iron Works Corp., 559 A.2d 340 (Me. 1989).
Moreau v. S.D. Warren Co., 2000 ME 62 (Me. 2000).
— Me. Rev. Stat. tit. 39, § 51-B(5) — 2 cases
Bridgeman v. S.D. Warren Co., 2005 ME 38 (Me. 2005). “1989) (codified as amended at 39 M.R.S.A. § 51-B(5), (7) (Supp.1989), repealed by P.”
Tompkins v. Wade & Searway Constr. Corp., 612 A.2d 874 (Me. 1992). “See 39 M.R.S.A. §§ 51-B(5), 51-B(7). Receipt of such payments does not constitute an acceptance by the employee of the nature and scope of an employer’s liability or of the amount or duration of the compensation.”
— Me. Rev. Stat. tit. 39, § 51-B(7) — 11 cases
Wentworth v. Manpower Temp. Servs., 589 A.2d 934 (Me. 1991). “See 39 M.R.S.A. § 51-B (1989 & Supp.1990). In April 1987, after a hearing on Wentworth’s petition for award of compensation, the commission ordered Manpower to make the retroactive payments it owed to Wentworth for her periods of total and partial incapacity since January 1985…”
Bridgeman v. S.D. Warren Co., 2005 ME 38 (Me. 2005). “1989) (codified as amended at 39 M.R.S.A. § 51-B(5), (7) (Supp.1989), repealed by P.”
Stickles v. United Parcel Serv., 554 A.2d 1176 (Me. 1989). “39 M.R.S.A. § 51-B (Pamph.1988). We conclude that, by failing to file a notice of controversy within 44 days from the time an employee tells an employer that lost work time is caused by a work-related injury, the employer accepts compensability of the injury at the level of the…”
Marsella v. Bath Iron Works Corp., 585 A.2d 802 (Me. 1991). “39 M.R.S.A. § 51-B(3) (1989). The employer must then begin making compensation payments unless he files a notice of controversy with the Commission within that time.”
Moreau v. S.D. Warren Co., 2000 ME 62 (Me. 2000).
— Me. Rev. Stat. tit. 39, § 51-B(8) — 4 cases
Bridgeman v. S.D. Warren Co., 2005 ME 38 (Me. 2005). “1989) (codified as amended at 39 M.R.S.A. § 51-B(5), (7) (Supp.1989), repealed by P.”
Tompkins v. Wade & Searway Constr. Corp., 612 A.2d 874 (Me. 1992). “See 39 M.R.S.A. §§ 51-B(5), 51-B(7). Receipt of such payments does not constitute an acceptance by the employee of the nature and scope of an employer’s liability or of the amount or duration of the compensation.”
Croteau-Robinson v. Merrill Trust/Fleet Bank, 669 A.2d 763 (Me. 1996). “The shuttle-bus itself was nothing more than an adjunct of the parking lot, and should not be accorded immunity as a "rideshare program.”
Brian v. State Dep't of Conservation, 556 A.2d 1089 (Me. 1989).
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