Maine Revised Statutes

Me. Rev. Stat. tit. 39, § 51 (2026)

Entitlement to compensation and services generally

✓ current as of May 2026
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(REPEALED)
SECTION HISTORY
PL 1967, c. 374, §1 (AMD). PL 1975, c. 480, §6 (AMD). PL 1981, c. 200 (RPR). PL 1987, c. 252 (AMD). PL 1991, c. 615, §D3 (AMD). PL 1991, c. 885, §A7 (RP). PL 1991, c. 885, §§A9-11 (AFF).
Notes of Decisions
Cited in 64 cases, 1969–2009 · leading case: Comeau v. Maine Coastal Servs., 449 A.2d 362 (Me. 1982).
Comeau v. Maine Coastal Servs., 449 A.2d 362 (Me. 1982). · cites it 5× “" 39 M.R.S.A. § 51. Although the opinion studiously avoids the use of the term, it undeniably adopts, for the first time in the law of Maine, the so-called "quantum theory" of work-connection.”
Ross v. Oxford Paper Co., 363 A.2d 712 (Me. 1976). · cites it 5× “The new standard for entitlement to compensation under 39 M.R.S.A. § 51 was to be “personal injury” and not the previously prescribed “personal injury by accident.”
Caron v. Maine Sch. Admin. Dist. No. 27, 594 A.2d 560 (Me. 1991). · cites it 6× “Pursuant to 39 M.R.S.A. § 51(3), 1 Caron filed a petition for *562 award of compensation with the Workers’ Compensation Commission alleging that her depression was caused by stress created by her employment.”
Brackett v. A.C. Lawrence Leather Co., 559 A.2d 776 (Me. 1989). · cites it 6× “See 39 M.R.S.A. § 51 (Supp.1988) (entitlement for compensation for injuries arising out of and in the course of employee's employment).”
Knox v. Combined Ins. Co. of Am., 542 A.2d 363 (Me. 1988). · cites it 3× “3 Combined specifically argued that Knox’s alleged injuries were compensable under the criteria in 39 M.R.S.A. § 51(1). 4 In support of its summary judgment motion, Combined submitted an affidavit from *365 one of its executives, purporting to show that Combined maintained a…”
Pratt v. Fraser Paper, Ltd., 2001 ME 102 (Me. 2001). · cites it 4× “1996), interpreted former 39 M.R.S.A. § 51(4) (Supp.1992), repealed and replaced by P.”
Townsend v. Maine Bureau of Pub. Saf., 404 A.2d 1014 (Me. 1979). · cites it 2× “39 M.R.S.A. § 51. The claimant testified that she was subjected to work-related “harassment” beginning in the winter of 1973 due to a relationship she had with a state police officer which the Department attempted to discourage.”
Bernier v. Data Gen. Corp., 2002 ME 2 (Me. 2002). · cites it 2× “Section 201(5) is based on a predecessor statute, former 39 M.R.S.A. § 51(4) (Supp.1992), which contained identical language and included the phrase “under this Act.”
Mushero v. Lincoln Pulp & Paper Co., 683 A.2d 504 (Me. 1996). · cites it 5× “39 M.R.S.A. § 51(4) (Supp.1992). 1 Mushero contends that because the work and nonwork-injuries were related to the same body part and contributed to his incapacitated condition, the injuries must be said to be “causally connected” for purposes of subsection 51(4), and therefore…”
Towle v. Dep't of Transp., State High., 318 A.2d 71 (Me. 1974). · cites it 4× “The Legislature did not define for us what it intended by the use of the words "personal injury by accident" as used in the context of 39 M.R.S.A. § 51. In Patrick v. Ham, 1921, 119 Me.”
Cole v. Chandler, 2000 ME 104 (Me. 2000). “The applicable section in Knox was 39 M.R.S.A. § 51(1), which has been repealed and replaced by 39-A M.”
Dorey v. Forster Mfg. Co., 591 A.2d 240 (Me. 1991). · cites it 2× “employment" language of 39 M.R.S.A. § 51 to the facts of this case.”
— Me. Rev. Stat. tit. 39, § 51(1) — 13 cases
Knox v. Combined Ins. Co. of Am., 542 A.2d 363 (Me. 1988). “3 Combined specifically argued that Knox’s alleged injuries were compensable under the criteria in 39 M.R.S.A. § 51(1). 4 In support of its summary judgment motion, Combined submitted an affidavit from *365 one of its executives, purporting to show that Combined maintained a…”
Cole v. Chandler, 2000 ME 104 (Me. 2000). “The applicable section in Knox was 39 M.R.S.A. § 51(1), which has been repealed and replaced by 39-A M.”
Cust v. Univ. of Maine, 2001 ME 29 (Me. 2001).
Harding v. Sheridan D. Smith, Inc., 647 A.2d 1193 (Me. 1994).
Morse v. Laverdiere's Super Drug Store, 645 A.2d 613 (Me. 1994).
— Me. Rev. Stat. tit. 39, § 51(2) — 2 cases
Boyce v. Potter, 642 A.2d 1342 (Me. 1994).
— Me. Rev. Stat. tit. 39, § 51(3) — 1 case
Caron v. Maine Sch. Admin. Dist. No. 27, 594 A.2d 560 (Me. 1991). “Pursuant to 39 M.R.S.A. § 51(3), 1 Caron filed a petition for *562 award of compensation with the Workers’ Compensation Commission alleging that her depression was caused by stress created by her employment.”
— Me. Rev. Stat. tit. 39, § 51(3)(A) — 1 case
Caron v. Maine Sch. Admin. Dist. No. 27, 594 A.2d 560 (Me. 1991). “Pursuant to 39 M.R.S.A. § 51(3), 1 Caron filed a petition for *562 award of compensation with the Workers’ Compensation Commission alleging that her depression was caused by stress created by her employment.”
— Me. Rev. Stat. tit. 39, § 51(3)(B) — 1 case
Caron v. Maine Sch. Admin. Dist. No. 27, 594 A.2d 560 (Me. 1991). “Pursuant to 39 M.R.S.A. § 51(3), 1 Caron filed a petition for *562 award of compensation with the Workers’ Compensation Commission alleging that her depression was caused by stress created by her employment.”
— Me. Rev. Stat. tit. 39, § 51(4) — 5 cases
Pratt v. Fraser Paper, Ltd., 2001 ME 102 (Me. 2001). “1996), interpreted former 39 M.R.S.A. § 51(4) (Supp.1992), repealed and replaced by P.”
Bernier v. Data Gen. Corp., 2002 ME 2 (Me. 2002). “Section 201(5) is based on a predecessor statute, former 39 M.R.S.A. § 51(4) (Supp.1992), which contained identical language and included the phrase “under this Act.”
Mushero v. Lincoln Pulp & Paper Co., 683 A.2d 504 (Me. 1996). “39 M.R.S.A. § 51(4) (Supp.1992). 1 Mushero contends that because the work and nonwork-injuries were related to the same body part and contributed to his incapacitated condition, the injuries must be said to be “causally connected” for purposes of subsection 51(4), and therefore…”
Kotch v. Am. Prot. Servs., Inc., 2002 ME 19 (Me. 2002).
Roy v. Bath Iron Works, 952 A.2d 965 (Me. 2008).
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