The Maine Supreme Judicial Court recently ruled that Carol Brewster is entitled to death benefits from her ex-husband’s employer, S.D. Warren/Sappi North America. This decision, made on August 6, 2026, clarifies the requirements for dependency in workers’ compensation cases. It affects individuals seeking benefits after the death of a former spouse due to work-related injuries.
The case stems from Brewster's petition for death benefits following the death of her ex-husband, Donald Nadeau, who passed away due to complications from injuries sustained while working for S.D. Warren in 1985. The court's ruling signifies that a person only needs to prove dependency at the time of the employee's injury to qualify for benefits, rather than at the time of death.
In this case, Brewster and Nadeau were married when he was injured in a workplace accident. They divorced in 1997, but Brewster filed for benefits after Nadeau died in September 2020. The Workers’ Compensation Board Administrative Law Judge (ALJ) initially ruled in Brewster's favor, stating that she was dependent on Nadeau at the time of his injury. S.D. Warren appealed this decision, arguing that Brewster should have been dependent at both the time of injury and death.
The dispute centers around the interpretation of 39 M.R.S.A. § 58, which outlines the eligibility for death benefits. S.D. Warren contended that the statute requires proof of dependency at both times, while Brewster argued that dependency at the time of injury is sufficient. The ALJ agreed with Brewster, leading to S.D. Warren's appeal to the Appellate Division of the Workers’ Compensation Board.
The Appellate Division upheld the ALJ's decision, stating that Brewster met the definition of “dependent” under the law. S.D. Warren then sought further review from the Maine Supreme Judicial Court, which ultimately affirmed the Appellate Division’s ruling.
The court's opinion, delivered by Justice Lawrence, emphasized the unambiguous language of section 58. The ruling stated, “the plain language of the statute… compels us to conclude… that section 58 requires only that a claimant be dependent on the injured employee at the time of injury to qualify for death benefits.” This clarification means that former spouses may still be eligible for benefits even if they are no longer dependent at the time of the employee's death.
The ruling has significant implications for individuals in similar situations. It establishes that dependency determinations are fixed at the time of injury, providing clarity for both workers and employers. The court noted that this interpretation aligns with the legislative intent behind the Workers’ Compensation Act, which aims to support dependents of employees and ensure that the burden of workplace injuries is borne by industry.
Moving forward, this decision may influence how courts interpret dependency in future workers’ compensation cases. It sets a precedent that could benefit other former spouses or dependents seeking benefits after the death of a worker due to a work-related incident.
As for the future of this case, S.D. Warren has the option to appeal to a higher court, but details regarding any potential appeal were not available in the court filing. There are no related cases pending that directly address this specific issue of dependency in workers’ compensation claims.