Justia Massachusetts Supreme Court Opinion SummariesArticles Posted in Contracts
Huang v. Ma
In this case concerning the law involving breach of an exclusive real estate broker agreement, the Supreme Judicial Court held that an enforceable contract was created in this case, Defendants committed a breach of that contract, and Plaintiff was entitled to her expectation damages.Plaintiff, a licensed real estate broker and her wholly-owned real estate brokerage firm, brought this action against Defendants, two former clients, after Plaintiff performed substantial services pursuant to the contract and Defendants terminated their relationship without paying her. Because there was no written agreement for brokerage services the motion judge granted summary judgment for Defendants. The Appeals Court reversed on the grounds that there is an express exemption to the Statute of Frauds for real estate brokers. The Supreme Judicial Court affirmed, holding that there was sufficient evidence to conclude that a contract was former and that a breach occurred, entitling Plaintiff to her expectation damages. View "Huang v. Ma" on Justia Law
Ken’s Foods, Inc. v. Steadfast Insurance Co.
The Supreme Judicial Court held that there is no common-law duty for insurers to cover costs incurred by an insured to prevent imminent covered loss when the plain, unambiguous terms of the insurance policy speak directly to the question of mitigation and reimbursement and do not provide coverage and the costs are otherwise excluded by other policy provisions.Insured sought recovery from Insurer for various costs it incurred after a wastewater treatment system at its manufacturing facility malfunctioned, claiming coverage under its pollution liability policy. In dispute were costs incurred that were not cleanup costs or costs necessary to avoid imminent endangerment to public health or welfare but necessary to avoid a business interruption. The district court held that the costs at issue were not recoverable and that there was no basis to impose a common-law duty that was inconsistent with the policy's coverages and exclusions. View "Ken's Foods, Inc. v. Steadfast Insurance Co." on Justia Law
Le Fort Enterprises, Inc. v. Lantern 18, LLC
The Supreme Judicial Court affirmed the decision of the district court granting summary judgment in favor of Seller in this case stemming from the economic disruption caused by the COVID-19 pandemic, holding that there was no error in the proceedings below.Specifically at issue was, in light of the disruptions caused by COVID-19 pandemic, whether the doctrines of impracticability of performance or frustration of purpose temporarily excused the purchaser of a cleaning services franchise and the purchaser's co-owners from their obligation to pay the outstanding portion of the purchase price of the franchise. The district court granted summary judgment in favor of the property seller. The First Circuit affirmed, holding (1) the record did not support a rational finding that the pandemic cause date continued payment of the franchise purchase price to be impracticable or frustrated the principal purpose of the contract; and (2) the parties intended that the obligation to pay would not be conditioned on the franchise's financial performance beyond the first six months following the sale. View "Le Fort Enterprises, Inc. v. Lantern 18, LLC" on Justia Law
Graycor Construction Co. v. Pacific Theatres Exhibition Corp.
The Supreme Court held that because court orders issued in the early months of the COVID-19 pandemic pursuant to the Court's superintendence authority under Mass. Gen. Laws ch. 221, 3 concerned court operations only and did not apply to executive agencies such as the registry of deeds, and therefore, a measure tolling statutory deadlines must be read as tolling only those deadlines that pertained to cases pending in court or to be filed in court.During the pandemic, Contractor sought to establish a mechanic's lien on land leased to Developer. Although Contractor recorded a notice of contract in the registry of deeds the notice failed to name the actual owners of the property. Contractor subsequently filed a complaint seeking to enforce the mechanic's lien. By the time Contractor recorded a property notice of contract in the registry of deeds the statutory deadline for making that recording had expired. Thereafter, Contractor brought claims against Owners for quantum merit, unjust enrichment, and for summary discharge of the mechanic's lien. The superior court judge allowed Contractor's motion to dismiss Owners' complaint for discharge. The Supreme Court reversed and allowed Contractor's motion to dismiss the complaint for summary discharge, holding that the emergency orders issued by the court did not apply to executive agencies. View "Graycor Construction Co. v. Pacific Theatres Exhibition Corp." on Justia Law
Posted in: Contracts
Willitts v. Brogan
The Supreme Judicial Court affirmed the judgment of the single justice of the court treating Petitioner's letter filed in the county court as a petition pursuant to Mass. Gen. Laws ch. 211, 3 and denying it, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner performed certain plumbing work for Defendants, and four different trial court cases stemmed from that work. Petitioner filed his letter seeking relief from various trial court rulings and judgments in the four district and superior court cases. The single justice treated the letter as a petition pursuant to Mass. Gen. Laws ch. 211, 3 and denied it. The Supreme Judicial Court affirmed, holding that, in each of the four cases, Petitioner had an adequate alternative remedy. View "Willitts v. Brogan" on Justia Law
Posted in: Contracts
Masonic Temple Ass’n of Quincy, Inc. v. Patel
The Supreme Judicial Court affirmed the judgments of the trial court entering summary judgment in favor of Defendants and denying Plaintiffs' motion to amend their complaint, holding that the trial court did not err or abuse its discretion.The Masonic Temple Association of Quincy, Inc. entered into a purchase and sale agreement with a trust under which the trust would develop the Mason's temple building into two condominium units, with the trust becoming the owner of one unit. The trust later assigned its interest to Jay Patel, the president and sole owner of Dipika, Inc. Later a fire broke out at the site. The Masons brought negligence claims against Patel and Dipika. Dipika brought third-party claims against Union Insurance Company for wrongful denial of coverage and Roblin Insurance Agency for professional negligence. The Masons then amended their complaint to assert claims against Union and Roblin. The superior court granted summary judgment in favor of Union and Roblin on all counts. The Supreme Judicial Court affirmed, holding (1) Dipika's putative liabilities arising from the fire were not covered by its general liability insurance policy; and (2) Dipika's insurance broker did not commit a breach of its duty of care. View "Masonic Temple Ass'n of Quincy, Inc. v. Patel" on Justia Law
Verveine Corp. v. Strathmore Insurance Co.
The Supreme Judicial Court affirmed the judgment of the superior court concluding that the insurance policies of three restaurants (Plaintiffs), which suffered reductions in revenues during the COVID-19 pandemic and the resulting government restrictions on public gatherings, did not unambiguously cover Plaintiffs' losses, holding that there was no error.Plaintiffs brought a declaratory judgment action to determine the scope of their policies. The superior court granted judgment against Plaintiffs, finding that there was no "direct physical loss or damage" resulting from the COVID-19 virus. The Supreme Judicial Court affirmed, holding that Plaintiffs' claims were properly dismissed. View "Verveine Corp. v. Strathmore Insurance Co." on Justia Law
CP 200 State, LLC v. CIEE, Inc.
The Supreme Judicial Court held that the doctrine of present execution does not permit an interlocutory appeal from a superior court judge's order denying a motion to enforce an alleged settlement agreement.Plaintiff filed this action asserting claims for summary process eviction and breach of contract regarding Defendant's lease of office space. The parties' counsel engaged in settlement negotiations via e-mail. Thereafter, Defendant moved to enforce what it asserted was a binding settlement agreement. After the motion judge denied the motion Defendant filed a petition for interlocutory review asserting that its interlocutory appeal was proper under the doctrine of present execution. A single justice presented questions for appellate review. The Supreme Judicial Court dismissed the appeal, holding that Defendant was not entitled to an interlocutory appeal under the doctrine of present execution. View "CP 200 State, LLC v. CIEE, Inc." on Justia Law
Nemirovsky v. Daikin North America, LLC
The Supreme Judicial Court affirmed the superior court judge's directed verdict in favor of DACA Delaware Dissolution Trust (DACA Trust) and Stebbins Duffy, a manufacturer's representative of Daikin Industries' products, on Ofer Nemirovsky's claims for breach of the implied warranty of merchantability and vacated the judgment entered against Daikin North America, LLC (Daikin NA), holding that the court erred in part.The trial judge declined to apply the "component parts doctrine" to the nondefective component distributed by Daikin NA because the component was not itself a "standalone" product and was designed specifically for use in the integrated product. The judge then granted directed verdict for Defendants on Nemirovsky's claims for breach of the implied warranty of merchantability against the original sellers of the HVAC system. The Supreme Judicial Court (1) vacated the judgment entered against Daikin NA, holding that the component parts doctrine precluded liability; and (2) affirmed the judge's directed verdict for Defendants on Nemirovsky's claims for breach of the implied warranty of merchantability against the original sellers of the HVAC system, holding that the claims were time barred. View "Nemirovsky v. Daikin North America, LLC" on Justia Law
McGilloway v. Safety Insurance Co.
The Supreme Judicial Court remanded these consolidated actions against two insurance companies to the superior court for further proceedings, holding that inherent diminished value (IDV) damages, if adequately proved, are recoverable under part 4 of the standard Massachusetts automobile insurance policy, 2008 edition.The three plaintiffs in these actions each owned an automobile that was involved in a collision with an automobile owned or operated by a party insured by either of the two insurance company defendants. Defendants compensated Plaintiffs' for the cost to repair their automobiles to their precollision condition but did not pay Plaintiffs for alleged IDV damages to the vehicles. The judge granted summary judgment in favor of Defendants. The Supreme Judicial Court vacated the judgment in part and affirmed in part, holding (1) the motion judge erred in allowing summary judgment with respect to Plaintiffs' claims of breach of contract; and (2) the motion judge properly granted summary judgment in favor of Defendants on Plaintiffs' unfair business practices claims. View "McGilloway v. Safety Insurance Co." on Justia Law