Massachusetts General Laws

Mass. Gen. Laws ch. 152, § 51 (2026)

Natural increase considered in determining weekly wages

✓ current as of July 2026

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Section 51. Whenever an employee is injured under circumstances entitling him to compensation, if it be established that the injured employee was of such age and experience when injured that, under natural conditions, in the open labor market, his wage would be expected to increase, that fact may be considered in determining his weekly wage. A determination of an employee's benefits under this section shall not be limited to the circumstances of the employee's particular employer or industry at the time of injury.

Notes of Decisions

Cited in 13 cases, 1950–2012 · leading case: Wadsworth's Case, 963 N.E.2d 1181 (Mass. 2012).

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Wadsworth's Case, 963 N.E.2d 1181 (Mass. 2012). · cites it 5× “He also claimed under G. L. c. 152, § 51, that, when he was injured in 1980, he was of “such age and experience .”

Walker's Case, 901 N.E.2d 1227 (Mass. 2009). · cites it 3× “At issue now is the application of G. L. c. 152, § 51 A, 1 in the unusual circumstances of this case, in which Walker’s entitlement to compensation for his injuries was established by a reviewing board decision that was subsequently amended by the board itself and then reversed…”

McLeod's Case, 450 N.E.2d 612 (Mass. 1983). “454, 457 (1948), if the Legislature had intended a contrary result in the circumstances contemplated by G. L. c. 152, § 51 A, it would have explicitly so provided.”

Sliski's Case, 676 N.E.2d 441 (Mass. 1997). · cites it 2× “Claims were filed and consolidated against both insurers to establish an average weekly wage under G. L. c. 152, § 51, which protects young employees who are injured early in their careers by including expected wage increases in the determination of such average weekly wage, the…”

Phillips's Case, 672 N.E.2d 122 (Mass. App. Ct. 1996). · cites it 2× “2 In his cross-appeal, Phillips contends that it was error for the board to reverse the administrative judge’s application of G. L. c. 152, § 51 A, which had allowed Phillips the maximum benefit rate because Arrow had refused to compensate Phillips prior to the judge’s decision.”

Louis's Case, 676 N.E.2d 791 (Mass. 1997). “Reference back to Sliski’s initial injury was appropriate under G. L. c. 152, § 51 (1994 ed.), which addresses the situation of young employees injured early in their careers and instructs us that an employee’s benefits are “not [to] be limited to the circumstances of the…”

Wadsworth's Case, 935 N.E.2d 333 (Mass. App. Ct. 2010). · cites it 3× “The first measure resulted from the imputed loss of expected income enhancement authorized by G. L. c. 152, § 51 (§ 51). The second was a heightened level of compensation granted to a worker who had returned to employment after a disabling injury but who then suffered a…”

Bursey's Case, 92 N.E.2d 583 (Mass. 1950). “On the other hand, in the enactment of the General Laws not only the definition of ''average weekly wages ” was substantially retained but no change of importance was made in St.”

Mugford's Case, 701 N.E.2d 654 (Mass. App. Ct. 1998). “In that decision, the administrative judge requested supplemental briefs from the parties on the applicability of G. L. c. 152, § 51 A. 2 In a “corrected decision” dated April 24,1990, the administrative judge found that § 51A applied to the case and ordered the insurer to pay…”

Conte v. P.A.N. Constr. Co., 746 N.E.2d 162 (Mass. App. Ct. 2001). “The reviewing board allowed Aetna credit for the payments it had previously made pursuant to the New Jersey statute, but did not consider the possible application of G. L. c. 152, § 51 A. Aetna thereafter paid Conte an additional $42,157.”

Biagini's Case, 526 N.E.2d 1303 (Mass. App. Ct. 1988). “431, 435 (1983): “We think it more likely that G. L. c. 152, § 51 A, reflects a legislative intent to avoid obsolescence of compensation rates by requiring benefits to be computed in accordance with the statutory rate in effect at the time of the final decision, when no payments…”

Camara's Case, 878 N.E.2d 941 (Mass. App. Ct. 2007). “In concluding that the employee’s § 34B cost of living adjustment should be based on the October 23, 1987, date of his original injury, instead of the February 4,1994, date of his subsequent injury, the reviewing board compared the rate adjusting provisions of § 35B, applicable…”

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