Justia Massachusetts Supreme Court Opinion SummariesArticles Posted in Arbitration & Mediation
Archer v. Grubhub, Inc.
The Supreme Judicial Court held that delivery drivers that delivered takeout food and various prepackaged goods from local restaurants, convenience stores, and delicatessens to Grubhub, Inc. do not fall within a residual category of workers who are exempt from arbitration pursuant to section 1 of the Federal Arbitration Act (FAA).Plaintiffs, former delivery drivers for Grubhub, brought this putative class action against Grubhub, alleging violations of the Wage Act, the Tips Act, and the Minimum Wage Act and that Grubhub unlawfully retaliated against drivers who complained about their wages. Grubhub filed a motion to compel arbitration pursuant to an arbitration agreement each Plaintiff had entered into. Because Plaintiffs transported and delivered some prepackaged food items manufactured outside Massachusetts, the judge found that Plaintiffs fell within the definition of "any other class of workers engaged in foreign or interstate commerce" who were exempt from arbitration under section 1 of the FAA. The Supreme Judicial Court reversed, holding that Plaintiffs were not transportation workers actually engaged in the movement of goods in interstate commerce, as required by the residual clause of section 1. View "Archer v. Grubhub, Inc." on Justia Law
Kauders v. Uber Technologies, Inc.
The Supreme Judicial Court held that this action against Uber Technologies, Inc. and Easier, LLC (collectively, Uber) was not arbitrable because there was no enforceable agreement between Uber and Plaintiffs.Plaintiffs brought this action under Mass. Gen. Laws ch. 272, 98A claiming that three Uber drivers refused to provide one plaintiff with rides because he was blind and accompanied by a guide dog. Citing a provision in Uber's cellular telephone application, which Plaintiffs had used to register with Uber, Uber moved to compel arbitration. The judge granted the motion. The arbitrator ruled in favor of Uber on all claims. Thereafter, the United States Court of Appeals for the First Circuit held in Cullinane v. Uber Technologies, Inc., 893 F.3d 53 (1st Cir. 2018) that Uber's registration process did not create a contract. Thereafter, the judge reversed his decision granting the motion to compel arbitration, concluding that there was no enforceable contract requiring arbitration. The Supreme Judicial Court remanded the case, holding (1) Uber's terms and conditions did not constitute a contract with Plaintiffs; and (2) therefore, Uber could not enforce the terms and conditions against Plaintiffs, including the arbitration agreement. View "Kauders v. Uber Technologies, Inc." on Justia Law
Landry v. Transworld Systems Inc.
The Supreme Judicial Court affirmed the judgment of the superior court denying Defendant's motion to compel arbitration of Plaintiff's claims that Defendant had engaged in improper debt collection practices and debt collection regulations, holding that there was no error in the denial of Defendant's motion to compel arbitration.Plaintiff allegedly owed debt to Enterprise Rent-A-Car Company of Boston, LLC for damage to a rental vehicle. Enterprise assigned the debt to Defendant for collection. Plaintiff filed a class action complaint against Defendant, alleging that Defendant made too frequent phone contact with him and other debtors. Defendant sought to compel arbitration of Plaintiff's claims pursuant to the rental contract between Plaintiff and Enterprise. The superior court denied the motion to compel. The Supreme Court affirmed, holding that reasonable minds could differ as to whether the arbitration provision in the contract was applicable to claims brought against Defendant, and therefore, Defendant did not put forth the clear and definite evidence of intent that it must to be entitled to enforce the arbitration provision as a third-party beneficiary. View "Landry v. Transworld Systems Inc." on Justia Law
GGNSC Administrative Services, LLC v. Schrader
In this wrongful death action brought against a nursing home notwithstanding the existence of an arbitration agreement between the decedent and the nursing home the Supreme Judicial Court answered two certified questions by holding that the Legislature intended wrongful death actions to be derivative of the decedent's own cause of action and that, under the circumstances of this case, the arbitration agreement between the decedent and the nursing home controlled the decedent's statutory beneficiaries.After the decedent died in a nursing home, Plaintiff, her daughter, brought this wrongful death action. The United States Court of Appeals for the First Circuit certified two questions to the Supreme Judicial Court. The Supreme Court answered (1) the wrongful death statute, Mass. Gen. Laws ch. 229, 2, provides rights to statutory beneficiaries derivative of, rather than independent from, what would have been the decedent's action for the injuries causing her death; and (2) the arbitration clause in this case was enforceable. View "GGNSC Administrative Services, LLC v. Schrader" on Justia Law
City of Pittsfield v. Local 447 International Brotherhood of Police Officers
The Supreme Judicial Court affirmed the order of the superior court judge confirming an arbitration award, holding that the award did not violate public policy under the circumstances of this case.Employee, a police officer, was terminated from his position as a police officer in the Pittsfield police department for making false statements. Thereafter, Employee’s union (Union) filed a grievance under a collective bargaining agreement between the Union and the City of Pittsfield. An arbitrator found that there was not just cause for termination and reinstated Employee. The City commenced an action pursuant to Mass. Gen. Laws ch. 150C, 11 to vacate the arbitrator’s award, arguing that it was contrary to public policy. A superior court judge confirmed the arbitration award. The Supreme Court affirmed, holding that where the arbitrator found that Employee’s statements were not intentionally false and did not lead to a wrongful arrest of prosecution or result in any deprivation of liberty or denial of civil rights, the arbitrator’s award of reinstatement did not violate public policy. View "City of Pittsfield v. Local 447 International Brotherhood of Police Officers" on Justia Law
WorldWide TechServices, LLC v. Commissioner of Revenue
This litigation began when purchasers of computer service contracts filed a putative class action against the sellers. The sellers successfully moved to compel arbitration pursuant to the terms of the computer services contracts. The sellers, in the meantime, had applied for tax abatements from the Commissioner of Revenue. The Commissioner denied the applications, and the sellers petitioned the Appellate Tax Board. Appellant, one of the consumers who purchased these service contracts, moved to intervene in the proceedings, which petition the Board allowed. The Board reversed the Commissioner’s decision and allowed the abatements. Taxes were imposed on the service contracts purchased by Appellant. After final judgment was entered in the sellers’ favor in the class action litigation, the sellers withdrew their tax abatement petitions with prejudice. The Board denied Appellant’s motion to strike the withdrawals and terminated the proceedings. The Supreme Judicial Court reversed, holding (1) the Board did not err as a matter of law in allowing the Sellers’ withdrawals; but (2) the Board’s termination of the proceedings in their entirety, after permitting Appellant to intervene and allowing the abatements, was an error of law. Rather, Appellant should have been allowed to proceed as an intervener on its claim to recover the taxes imposed on the service contracts it purchased. View "WorldWide TechServices, LLC v. Commissioner of Revenue" on Justia Law
City of Boston v. Boston Police Patrolmen’s Association
It was not appropriate to vacate the arbitration award in this case concerning the termination of a police officer.The City of Boston terminated David Williams, a Boston police officer, for using a choke hold in arrested an unarmed suspect for disorderly conduct and making false statements in a departmental investigation. An arbitrator found no underlying misconduct on the part of the officer and ruled that the City of Boston lacked just cause to terminate the officer and ordered his reinstatement. The City filed a complaint seeking to vacate the arbitrator’s award. The superior court dismissed the complaint. The Supreme Judicial Court affirmed, holding that it was not appropriate to vacate the arbitration award where the award neither exceeded the arbitrator’s authority nor violated public policy and where no underlying misconduct was found. View "City of Boston v. Boston Police Patrolmen's Association" on Justia Law
Katz, Nannis & Solomon, P.C. v. Levine
Plaintiffs and Defendant, members of an accounting firm (Firm), were parties to a stockholder agreement (Agreement) that contained an arbitration clause. The parties’ agreement to arbitrate was governed by the Massachusetts Uniform Arbitration Act for Commercial Disputes. When Plaintiffs voted to require the withdrawal of Defendant as a director and stockholder in the Firm, Defendant opened his own accounting firm. The nature and terms of Defendant’s withdrawal from the Firm and his subsequent competition with the Firm were the bases of a dispute between the parties. The dispute was submitted to binding arbitration. The arbitrator issued a final award awarding the Firm $1.7 million plus interest. The superior court confirmed the arbitration award. Defendant appealed, arguing (1) the arbitrator fundamentally misinterpreted the agreement, and (2) he was entitled to have a court consider the merits of his claim because, in the arbitration clause of the agreement, the parties specifically provided for judicial review of an award to determine if there was flagrant error by the arbitrator. The Supreme Judicial Court affirmed the motion judge’s confirmation award, holding (1) the grounds of judicial review in this case were limited to those delineated in Mass. Gen. Laws ch. 215, 12 and 13; and (2) Defendant’s claim was not reviewable by the Court. View "Katz, Nannis & Solomon, P.C. v. Levine" on Justia Law
Beacon Towers Condo. Trust v. Alex
After a fire broke out at the Beacon Towers Condominium, the board of trustees for the Beacon Towers Condominium Trust, the unit owners’ organization for the condominium, assessed George Alex $62,995 for the two units that he owned. Alex commenced an arbitration action challenging the propriety of the trustees’ conduct regarding the fire damage repairs and the imposition of the assessment. The arbitration panel found in favor of Alex. Although the panel recognized that the arbitration agreement in the trust’s bylaw did not provide for an award of fees, the panel nonetheless awarded fees, reasoning that the American Arbitration Association allowed an award of fees where “substantially all of the defenses were wholly insubstantial, frivolous and not advanced in good faith.” The trust filed suit, claiming that the arbitrators’ award of attorney’s fees exceeded the scope of the parties’ arbitration agreement. A superior court judge vacated the award of attorney’s fees, concluding that such an award was not authorized by Mass. Gen. Laws ch. 231, 6F when ordered by an arbitrator because section 6F does not authorize an arbitrator to award attorney’s fees. The Supreme Judicial Court affirmed, holding that an arbitrator lacks the authority to award attorney’s fees under the circumstances of this case. View "Beacon Towers Condo. Trust v. Alex" on Justia Law
Vale v. Valchuis
A stock transfer restriction required a selling shareholder first to offer his stock to the company at his desired price and then, if the company rejected it, to offer it at a price to be determined by arbitrators. Plaintiff invoked this process by tendering an offer to the company (Defendant) but later changed his mind regarding his desire to sell. When Plaintiff sought to withdraw from the process of valuing his stock, Defendant moved to compel arbitration. The superior court denied the motion to compel, concluding that a mere disagreement over the value of stock was legally insufficient to give rise to arbitration. The Supreme Judicial Court affirmed on other grounds, holding (1) a stock valuation may be conducted through arbitration so long as an actual controversy exists regarding the value of the stock; and (2) because the shareholder in this case decided not to sell the stock prior to the commencement of arbitration, the controversy to be arbitrated was rendered moot. View "Vale v. Valchuis" on Justia Law