Justia Massachusetts Supreme Court Opinion Summaries

Plaintiffs refinanced their home through Lender. The monthly payment on the loan was $600 greater than Plaintiffs' total monthly income. After the mortgage was funded, it was sold and assigned to Bank. Servicer serviced the loan. After Plaintiffs defaulted on the loan, Bank foreclosed on the mortgage. Plaintiffs subsequently brought this action asserting violations of the Consumer Protection Act, the Predatory Home Loan Practices Act, and the Borrower's Interest Act, and asserting that the loan was unenforceable because it was unconscionable. A superior court judge granted summary judgment to Defendants, Bank and Servicer, on all claims based on the ground that Defendants, as assignees, had no liability for the acts of Lender. The Supreme Court (1) reversed summary judgment in favor of Bank, holding that Bank was not shielded from liability as a matter of law by virtue of its status as an assignee and that Bank failed to establish the absence of material issues of disputed fact entitling it to judgment on any individual claim; and (2) affirmed summary judgment in favor of Servicer because Servicer was not shown to be an assignee and Plaintiffs offered no alternative basis on which Servicer might be held liable. Remanded. View "Drakopoulos v. U.S. Bank Nat'l Ass'n" on Justia Law

Karla Brown brought a lawsuit against Deutsche Bank and others seeking rescission of a note and first mortgage securing that note, alleging that she was the victim of a predatory lending scheme. The mortgage was originated by Deutsche Bank's predecessor in interest in connection with the purchase of Brown's home. Deutsche Bank requested that First American Title Insurance Company defend Deutsche Bank's mortgage interest pursuant to the terms of its title insurance policy. First American refused coverage, claiming the lawsuit did not trigger its duty to defend because Brown was claiming she was misinformed as to the terms of the note rather than challenging that she granted the mortgage. Deutsche Bank subsequently brought this action seeking a judgment declaring First American had a duty to defend it in Brown's lawsuit. The superior court granted summary judgment in favor of First American. The Supreme Court affirmed, holding that the allegations in Brown's complaint did not trigger First American's duty to defend because the complaint's claims were not specifically envisioned by the terms of the title insurance policy. View "Deutsche Bank Nat'l Ass'n v. First Am. Title Ins. Co." on Justia Law

Plaintiff, a janitorial cleaning services franchisee, along with franchisees from other states, filed a putative class action in the U.S. district court against Defendant, the Massachusetts corporation that franchised Plaintiff's business, alleging that Defendant misclassified him as an independent contractor and committed various wage law violations. The district court certified several questions of law to the Massachusetts Supreme Court, which answered by holding (1) a plaintiff's failure to exhaust administrative remedies pursuant to Mass. Gen. Laws ch. 150 by filing a complaint with the attorney general does not deprive a court of jurisdiction to consider Plaintiff's claims under Mass. Gen. Laws ch. 149, 148, 148B, 150, and 151(1) and (1a); (2) a franchisor is vicariously liable for the conduct of its franchisee only where the franchisor controls or has a right to control the specific policy or practice resulting in harm to the franchisee; and (3) a defendant may be liable for employee misclassification where there was no contract for service between the plaintiff and the defendant. View "Depianti v. Jan-Pro Franchising Int'l, Inc." on Justia Law

Plaintiffs were individuals who lived in New York and worked there as couriers for Defendant, a corporation headquartered in Massachusetts. Plaintiffs brought this action in a Massachusetts court to enforce certain Massachusetts independent contractor, wage, and overtime pay statutes. The superior court dismissed the complaint, concluding (1) the Massachusetts independent contractor statute does not apply to non-Massachusetts residents working outside Massachusetts, and (2) as independent contractors, Plaintiffs failed to state claims under the Massachusetts wage statutes. The Supreme Court vacated the judgment of dismissal and remanded for further proceedings, holding that, insofar as the written contract between the parties contained an enforceable clause requiring both that actions be brought in Massachusetts and requiring that the contract and all rights and obligations of the parties be determined under Massachusetts law, and where application of Massachusetts law is not contrary to a fundamental policy of the jurisdiction where the individuals live and work, it was error to dismiss Plaintiffs' complaint. View "Taylor v. E. Connection Operating, Inc." on Justia Law

Landlord and Tenant entered into a twelve-year lease for commercial space. The lease required a separate guaranty agreement to be executed by Guarantor. Tenant stopped making rent payments a couple of years later, and thereafter, Landlord reentered and took possession of the premises, thereby terminating the lease. Landlord subsequently filed suit against Tenant and Guarantor for damages arising from the breach of contract. The superior court granted summary judgment to Landlord as to liability and awarded damages in the amount of $1,092,653, for which Tenant and Guarantor were jointly liable. The appeals court affirmed in part and vacated the judgment assessing damages and remanded. The Supreme Court (1) affirmed the part of the judgment finding Tenant liable for breach of the lease and assessing damages for the period before termination of the lease in the amount of $37,276 plus prejudgment interest; and (2) vacated the part of the judgment assessing damages for the period following termination of the lease and awarding attorney's fees. View "275 Washington St. Corp. v. Hudson River Int'l, LLC" on Justia Law

Plaintiff purchased real property after a real estate broker gave him incorrect information about the zoning classification of the property. Plaintiff was thereafter unable to use the property as he intended. Plaintiff sued the broker and the real estate agency that employed her, alleging misrepresentation and violation of Mass. Gen. Laws ch. 93A, 2. The superior court granted summary judgment in favor of Defendants. The Supreme Court vacated the judgment, holding (1) a broker has a duty to exercise reasonable care in making representations as to a property's zoning designation, and where the misrepresentations were based on information provided by the seller, as in this case, the question of whether it was reasonable in the circumstances to rely on such information is to be determined by the trier of fact; and (2) an exculpatory clause in the purchase and sale agreement did not preclude the buyer's reliance on prior written representations as to zoning classification. View "DeWolfe v. Hingham Centre, Ltd." on Justia Law

This case involved multiple litigations among three parties - Insurer, insured Mortgagee, and Homeowner - arising out of a defect in the title to Homeowner's home. Insurer brought suit in the land court on behalf of Mortgagee seeking to reform the deed to the property or to equitably subrogate Homeowner's interest in the property behind Mortgagee's mortgage. Homeowner initiated suit in the superior court against Mortgagee. Eventually, all claims in both actions became part of a federal court case, which settled. Thereafter, Mortgagee filed a complaint against Insurer in the U.S. district court seeking to recover from Insurer for the costs Mortgagee incurred in defending against Homeowner's claims. The judge determined Insurer had no obligation under its title insurance policy to pay Mortgagee's defense costs but certified two questions to the Massachusetts Supreme Court. The Court answered by holding that, under Massachusetts law (1) a title insurer does not have a duty to defend the insured in the entire lawsuit where one claim is within the scope of the title insurance coverage and other claims are not; and (2) a title insurer that initiates litigation similarly does not have a duty to defend the insured against all reasonably foreseeable counterclaims. View "GMAC Mortgage, LLC v. First Am. Title Ins. Co." on Justia Law

Defendant purchased an "own occupation" disability insurance policy from an affiliate of Plaintiff, Metropolitan Life Insurance Company (MetLife). After Defendant was diagnosed with cancer, Defendant's employment was terminated. Defendant filed a clam for disability benefits and began receiving disability payments. Defendant later began working at a lower stress job. MetLife concluded that Defendant was no longer eligible to receive disability benefits. Metlife reached this conclusion by interpreting a clause in Defendant's policy requiring Defendant to receive care by a physician that "is appropriate for the condition causing the disability" to mean that Defendant was required to pursue treatment aimed at returning him to his prior occupation. MetLife filed an action seeking a judgment declaring it had no continuing obligation to pay benefits to Defendant and reimbursement of benefits it had paid. The superior court declared MetLife was not required to continue paying Defendant benefits but that MetLife was not entitled to restitution of any benefits paid. The Supreme Court affirmed, holding (1) Defendant was not entitled to benefits under the policy since he was not receiving care designed to enable him to return to him prior occupation; and (2) MetLife was not entitled to reimbursement for benefits paid to Defendant. View "Metro. Life Ins. Co. v. Cotter" on Justia Law

Construction Company contracted with Subcontractor for construction of elements of an HVAC system. As partial collateral for a revolving line of credit, Subcontractor assigned to Bank its right to receive payment under the contract with Construction Company. Construction Company instead made twelve payments to Subcontractor. Subcontractor subsequently ceased business operations, leaving an outstanding debt to Bank on its line of credit. Bank filed an action against Construction Company for breach of contract and violation of the UCC. A jury found (1) Construction Company liable on both counts for ten of the twelve checks that it had delivered to Subcontractor, and (2) Bank was estopped from recovering with respect to the final two checks. The judge entered judgment on the statutory claim in the amount of $3,015,000, the full face value of the ten checks. The Supreme Court affirmed in part and reversed in part, holding that the trial judge (1) properly entered judgment on Bank's statutory claim in the amount of the wrongfully midirected payments; but (2) erred in denying the bank's motion for partial judgment notwithstanding the verdict with respect to the final two checks, as there was insufficient evidence to support Construction Company's defense of estoppel. View "Reading Coop. Bank v. Constr. Co." on Justia Law

Plaintiff served as superintendent of schools in the town of North Brookfield until 2005. Plaintiff's employment contract provided that, on his retirement, Plaintiff would be reimbursed thereafter for a percentage of his health insurance premiums on an annual basis. In 2006, Plaintiff sent a request for reimbursement for a fixed percentage of the premium costs for his health insurance policy from the date of retirement. When the town refused to honor the request Plaintiff filed this action against the school committee and the town for breach of contract and specific performance of the contract. The superior court granted Plaintiff's motion for summary judgment. On appeal, Defendants argued that the obligation to reimburse Plaintiff for a percentage of his health insurance costs annually for his life signaled that Plaintiff's final employment contract was a lifetime agreement that exceeded six years in duration and therefore violated Mass. Gen. Laws 71, 41. The Supreme Court affirmed, holding that the employment contract at issue in this case was valid and enforceable even though the reimbursement clause would presumptively exceed six years, as a contract that has expired may include enforceable obligations to be performed by the parties thereafter. View "O'Neill v. Sch. Comm. of N. Brookfield" on Justia Law