Justia Massachusetts Supreme Court Opinion Summaries

John Marino, who died before this action, owned Corporation. Defendant sold equipment to Corporation, which failed to pay Defendant. Defendant obtained a default judgment against Corporation but was unable to enforce the judgment because Corporation had no assets. Defendant brought an action against Marino's estate, the executrix of Marino's estate, and another corporation owned by Marino, asserting claims for breach of contract, remedies under the Uniform Fraudulent Transfer Act (UFTA), violations of Mass. Gen. Laws ch. 93A, unjust enrichment, and fraud. Defendants filed a joint motion for judgment on the pleadings, arguing that none of the claims survived, as each claim arose from fraudulent acts or misrepresentations made by Marino. A superior court judge dismissed all claims against the estate. The Supreme Court affirmed in part and reversed in part, holding (1) the breach of contract, UFTA, and violations of Chapter 93A claims should not have been dismissed because the claims were contractual in nature; (2) the fraud claim was properly dismissed; and (3) the unjust enrichment claim should not have been dismissed because it was premised on the allegation that the executrix was retaining funds belonging to Defendant. Remanded. View "Kraft Power Corp. v. Merrill" on Justia Law

This case involved an employment dispute between Defendant, a home heating oil company, and Plaintiffs, two former delivery truck drivers. Plaintiffs argued that they were owed compensation based on their classification as employees, rather than as independent contractors, under the Wage Act. Defendant responded (1) Plaintiffs' claims were barred by the statute of limitations, and (2) alternatively, a general release contained in the parties' contract termination agreements nevertheless defeated the Wage Act claims. The superior court stayed the proceedings and reported the statute of limitations and general release issues to the appeals court. The Supreme Court transferred the case on its own motion and held (1) Plaintiffs were entitled to recover for damages that occurred within the three-year period prior to filing the complaint; (2) the general releases contained in the contract carrier termination agreements that did not explicitly include the release of Wage Act claims failed to waive those claims; and (3) as a result, Plaintiffs remained entitled to recover for their damages accruing within the three-year period prior to filing the lawsuit. View "Crocker v.Townsend Oil Co." on Justia Law

Plaintiff Creative Playthings Ltd., a Massachusetts corporation, entered into a franchising agreement with Defendant under which Defendant agreed to operate a Creative Playthings franchise store in Florida. Plaintiff later terminated its agreement with Defendant and commenced this action against Defendant in the U.S. district court for breach of contract and associated claims. Defendant filed several counterclaims against Creative. Creative moved for summary judgment on Defendant's counterclaims, asserting they were time barred under the limitations provision in the franchise agreement. The federal district court judge declined to decide Creative's motion and instead certified the question of whether contractually shortened statutes of limitations are generally enforceable under Massachusetts law. The Supreme Court answered by holding that, in a franchise agreement governed by Massachusetts law, a limitations period in the contract shortening the time within which claims must be brought is valid and enforceable under Massachusetts law if the claim arises under the contract and the agreed-upon limitations period is subject to negotiation by the parties, is not otherwise limited by controlling statute, is reasonable, is not a statute of repose, and is not contrary to public policy. View "Creative Playthings Franchising Corp. v. Reiser" on Justia Law

Petitioner filed suit in superior court claiming that she and her son entered into an oral that granted her a life estate in certain property. Petitioner sought to enforce the oral agreement or, in the alternative, recover of a theory of quantum meruit. The superior court granted summary judgment for Defendants. The appeals court remanded for proceedings as to whether Petitioner should recover under a theory of quantum meruit. While the case was pending on remand, Petitioner filed a petition in the county court against the judge assigned to the matter, in both his individual and official capacities, and against the Commonwealth. Petitioner raised a number of claims concerning the judge's rulings and conduct, including an assertion that he had acted in an unlawful and biased manner. The single justice denied the petition without a hearing. The Supreme Court affirmed, holding (1) Petitioner's claims of judicial bias and declaratory judgment claims should have been addressed through the ordinary trial and appellate process; (2) the judge was absolutely immune from Petitioner's request for monetary damages; and (3) Petitioner's allegations of conspiracy were insufficient to overcome the judge's absolute immunity. View "Johnson v. Commonwealth" on Justia Law

In two separate actions, seven Massachusetts hospitals and one managed health care organization that disproportionately provided medical care to the poor alleged that the Secretary of the Executive Office of Health and Human Services violated her obligation to reimburse them for the reasonable costs incurred in providing medical services to MassHealth enrollees. A superior court judge granted the Secretary's motion for judgment on the pleadings in one case and the Secretary's motion to dismiss in the other, concluding as a matter of law that the plaintiffs could not prevail even if their allegations were true. The plaintiffs appealed, and the cases were consolidated. The Supreme Court affirmed the decisions denying the plaintiffs' claims, holding that the plaintiffs' redress for their claims rested in the political arena, not in the courts. View "Boston Med. Ctr. v. Sec'y of the Executive Office of Health & Human Servs." on Justia Law

Plaintiff filed a complaint alleging that Defendant committed a breach of a settlement agreement with the town by failing to remove mulch from property owned by Plaintiff. Defendant filed a special motion to dismiss under the anti-SLAPP (Strategic Lawsuit Against Public Participation) statute, contending that the civil claim was intended to retaliate, deter, and punish Defendant solely for engaging in the constitutionally protected activity of petitioning the town. The motion was denied. On interlocutory appeal, the Supreme Court affirmed the denial, holding that Defendant failed to meet its required threshold showing that Plaintiff's claim of breach of the settlement agreement was based on Defendant's exercise of its right to petition. View "Marabello v. Boston Bank Corp." on Justia Law

An electrician was killed by electrocution while attempting to repair an electrical transformer at the Logan Airport Hilton Hotel (Hilton). Plaintiff, as administratrix of the electrician's estate, filed suit against, inter alia, Hilton, the architect who designed the hotel (Cambridge Seven), the consultant Cambridge Seven retained to provide electrical engineering services (Costentini), and the construction subcontractor for electrical services (Broadway), alleging negligence, gross negligence, and breach of warranty. Hilton and Broadway filed cross claims against Cambridge Seven and Cosentini for indemnification and contribution. The superior court granted the motion for summary judgment brought by Cambridge Seven and Cosentini as to the complaint and cross claims and ordered final judgment. Hilton and Broadway appealed. The Supreme Court (1) affirmed the grant of summary judgment on behalf of Cambridge Seven and Cosentini as to the cross claims brought by Hilton and Broadway for indemnification; but (2) reversed as to the cross claims for contribution. Remanded. View "LeBlanc v. Logan Hilton Joint Venture" on Justia Law

In 2004-2005, Costa & Son Construction performed site work for the general contractor (Braitt) on such a project in Bridgewater. After Braitt terminated the relationship Costa sued, alleging breach of contract and violations of G.L. c. 93A. Costa sought to recover damages under a payment bond obtained by Brait from Arch Insurance, G.L. c. 149, 29. Brait asserted similar counterclaims against Costa. Arch argued that Costa had relinquished any right to claim against the bond pursuant to a provision of his subcontract with Brait. The trial court granted Brait and Arch directed verdict with respect to claims under the bond. A jury returned a verdict for Costa, against Brait. The Massachusetts Supreme Court vacated the directed verdict. A subcontractor on a public construction project for which a payment bond has been obtained by the general contractor pursuant to G.L. c. 149, 29, may not by private agreement forgo its right to pursue payment under the bond. The court also vacated the portion of the amended judgment granting consequential damages to Costa; consequential damages were precluded by the contract. View "Costa v. Brait Builders Corp." on Justia Law

In 2000 Go-Best wired $5 million to an account entitled "Morris M. Goldings client account" at Citizens Bank, based on representations made by Morris M. Goldings, who was then a Massachusetts attorney. Goldings later admitted that the representations were false and that he had used the money to pay other debts. Go-Best filed suit against Citizens Bank, bringing claims of misrepresentation, conversion, aiding and abetting a fraud, aiding and abetting a breach of fiduciary duty, aiding and abetting a conversion, and negligence. Citizens Bank had no knowledge of Goldings's scheme to defraud Go-Best but failed to notify the Board of Bar Overseers of dishonored checks issued on the client account more than six months before Go-Best wired funds into that account. The trial court dismissed, but a divided Appeals Court reversed in part, vacating dismissal of claims of negligence and of aiding and abetting. The Massachusetts Supreme Court reinstated dismissal. Without actual knowledge, the bank's duty to notify the board of dishonored checks from trust accounts arose only from its contractual duty, not from any duty in tort, so the bank could not be liable to Go-Best for any negligence in fulfilling that duty. View "Go-Best Assets Ltd. v. Citizens Bank of MA" on Justia Law

The Regional School District (Mahar), entered into a price watch agreement with Northeast Energy Partners, a licensed broker of energy services based in Connecticut, pursuant to which Northeast would negotiate and secure contracts for the provision of Mahar's electricity from energy suppliers. Mahar did not enter into the agreement to obtain Northeast's services pursuant to the competitive bidding procedures contained in G.L. c. 30B. When Mahar questioned the validity of the agreement, Northeast sought a declaratory judgment that the agreement is valid and enforceable because, under G.L. c. 30B, 1 (b ) (33), the agreement is exempt from the competitive solicitation and bidding procedures set forth in G.L. c. 30B. The Massachusetts Supreme Court ruled in favor of Northeast, holding that a contract between a school district and an energy broker for procurement of contracts for electricity is exempt from the requirements of G.L. [c.] 30B as a contract for 'energy or energy related services' pursuant to G.L. c. 30B, 1 (b ) (33). View "NE Energy Partners, LLC v. Mahar Reg'l Sch. Dist." on Justia Law