Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Contracts
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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

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The Supreme Judicial Court held that the six-year statute of limitations for contract actions governed this case and that the efforts of Executive Office of Health and Human Services, Office of Medicaid (MassHealth) to collect overpayments made to providers in the State Medicaid program were time barred.In 2005, MassHealth sent an audit notice to a provider, Suburban Home Health Care, Inc., but took no further action until 2016, when it initiated recovery proceedings. Suburban sought declaratory relief, arguing that the proceedings were barred under the statute of limitations for "actions of contract" in Mass. Gen. Laws ch. 260, 2. The superior court denied relief, concluding that the administrative proceedings to collect the overpayments could not be considered civil actions, and therefore, no statute of limitations applied. The Supreme Judicial Court reversed, holding that the six-year statute of limitations for contract actions applied and that MassHealth's action was time barred. View "Suburban Home Health Care, Inc. v. Executive Office of Health and Human Services, Office of Medicaid" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court allowing Defendants' motion for judgment on the pleadings on the ground that the claims in this case were based on issues that had been litigating and decided in previous litigation between the same parties, holding that this action was precluded.In 2014, Plaintiff, the owner of the closely held corporation at the center of the parties' dispute, filed a complaint alleging that Defendants breached a contract and their fiduciary duties. The superior court judge found against Plaintiffs on his claims and found in favor of Defendants on their counterclaims. In 2017, Plaintiff brought this action alleging breach of contract and breach of fiduciary duty and asserting derivative claims. The superior court judge allowed Defendants' motion for judgment on the pleadings. The Supreme Judicial Court affirmed, holding (1) issue preclusion applied in this case; and (2) where the interests of the parties fully coincided with that of the closely held corporation, Plaintiff was precluded from asserting his claims by means of a derivative action. View "Mullins v. Corcoran" on Justia Law

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The Supreme Judicial Court vacated the portion of the trial court's judgment denying Plaintiff's claim under Mass. Gen. Laws ch. 93A, 11 and affirmed the remainder of the judgment, holding that the judge erred in instructing the jury under section 11.The attorney defendants in this case misappropriated propriety materials from their employer during their employment and subsequently used those materials to compete with their former employer. A jury found Defendants liable on claims for conversion, conspiracy, and breach of the duty of loyalty. The jury denied relief on the plaintiff employer's claims for unfair or deceptive trade practices, in violation of section 11. The Supreme Judicial Court vacated the judgment in part, holding that Defendants may be liable for unfair or deceptive trade practices, and the judge erred in instructing the jury that Defendants' conduct before leaving their employer was not relevant to Plaintiff's claim under section 11. View "Governo Law Firm LLC v. Bergeron" on Justia Law

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The Supreme Judicial Court vacated the superior court's judgment allowing Psychemedics Corporation's motion for summary judgment on its claim for declaratory relief against the City of Boston on the ground that it had no duty to indemnify the City on a suit brought against the City arising from positive drug hair tests by Psychemedics, holding that Psychemedics was not entitled to judgment as a matter of law.The City contracted with Psychemedics to conduct hair follicle tests for Boston police department officers to screen for the use of illicit drugs. The contracts included an indemnification clause in which Psychemedics agreed to assume the defense of the City and to hold it harmless from claims arising from wrongful or negligent acts by Psychemedics. When a number of officers, who had been terminated in connection with positive drug hair tests, sued the City, Psychemedics sought declaratory relief asserting that it had no duty to indemnify the City. The trial judge granted summary judgment for Psychemedics, concluding that the City had deprived Psychemedics of the opportunity of assuming the defense. The Supreme Judicial Court reversed, holding that the determination whether Psychemedics did in fact tender a defense that the City rejected should have been left to the trier of fact. View "Psychemedics Corp. v. City of Boston" on Justia Law

Posted in: Contracts
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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

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The Supreme Judicial Court affirmed the order of the superior court granting summary judgment to Northeastern University on Plaintiff's negligence-related claims stemming from a nonconsensual encounter with a fellow student, holding that, under the circumstances, Northeastern had no duty to protect Plaintiff.In her complaint, Plaintiff alleged that Northeastern negligently failed to prevent and contributed to the occurrence of the sexual assault. Plaintiff further asserted tort, contract, and statutory claims alleging that Northeastern failed adequately to respond to the incident. The Supreme Judicial Court affirmed, holding (1) a special student-university relationship between Plaintiff and Northeastern existed, but Northeastern owed no duty to protect Plaintiff because Northeastern could not reasonably have foreseen that, absent some intervention on its part, Plaintiff would be subjected to a criminal act or other harm; and (2) there was no error in the motion judge's conclusions regarding Plaintiff's statutory or contract claims. View "Helfman v. Northeastern University" on Justia Law

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In this action where the trial court allowed Defendant's special motion to dismiss, the Supreme Judicial Court held that Defendant was entitled to appellate attorney's fees under Mass. Gen. Laws ch. 184, 15(c).Plaintiffs and Defendant executed a written offer to purchase certain property. When discussions related to the purchase and sale agreement were unsuccessful Defendant notified Plaintiffs that it could not make the deal work. Plaintiffs commenced this action alleging breach of contract and other claims. Plaintiffs also applied for a memorandum of lis pendens, which was approved. Defendant filed a motion to dissolve the lis pendens and a special motion to dismiss the action. A judge denied the motion to dissolve the lis pendens but allowed the special motion to dismiss. The Appeals Court affirmed the judgment of dismissal but denied Defendant's request for appellate attorney's fees and costs. The Supreme Judicial Court reversed in part, holding that Defendant was entitled to an award of appellate attorney's fees and costs. View "DeCicco v. 180 Grant Street, LLC" on Justia Law

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The Supreme Judicial Court affirmed the order of the superior court finding that Defendant committed a breach of contract and the implied covenant of good faith and fair dealing and awarding $10.2 million in damages, holding that the superior court did not abuse its discretion.The jury awarded Plaintiff in excess of $22 million in damages after Defendant withdrew its support for Plaintiff's research laboratory. The judge conditionally ordered a new trial unless Plaintiff agreed to remit all but $10.2 million of the awarded damages, which represented in part $10 million that Plaintiff testified was necessary to reestablish her laboratory. The Supreme Judicial Court affirmed, holding (1) the trial evidence supported the finding that Defendant committed a breach of both the express terms of the contract and the implied covenant of good faith and fair dealing; (2) the cost of reestablishing the laboratory was a permissible element of the damages; and (3) the judge did not abuse her discretion in adding a remittitur of all but $10.2 million of the award of damages. The judges were equally divided as to whether the $10 million should go to Plaintiff outright or subject to a restriction, and therefore, the award of damages stood without any restriction. View "Hlatky v. Steward Health Care System, LLC" on Justia Law

Posted in: Contracts
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The Supreme Judicial Court vacated the trial judge's order setting aside the jury verdict and reinstated the original judgment in favor of Plaintiff, holding that the contract at issue in this appeal did not require an obligation that Plaintiff register as a securities broker-dealer under Massachusetts and Federal securities laws.Plaintiff sued Defendant alleging breach of contract, breach of the implied covenant of good faith and fair dealing, and violations of Mass. Gen. Laws ch. 93A. A jury found Defendant liable on all claims and awarded treble damages. Thereafter, the judge set aside the jury's verdict in its entirety, concluding that Plaintiff had been required to register as a securities broker-dealer and that its failure to do so rendered its contract with Defendant invalid and unenforceable. The contract required Plaintiff to "source capital and structure financing transactions from agreed-upon investors and/or lenders" for Defendant. The Supreme Judicial Court reversed, holding (1) the contract, on its face, did not require Plaintiff to "effect" transactions in "securities"; and (2) because Plaintiff's purported obligation to register as a broker-dealer was the sole basis for the judge's decision that Plaintiff could not maintain its breach of contract and Mass. Gen. Laws ch. 93A claims, the judge's decision to set aside the jury verdict was erroneous. View "NTV Management, Inc. v. Lightship Global Ventures, LLC" on Justia Law