Gem Plumbing and Heating Services, LLC v. Rusty's, Inc; Michael J. Roderick; Thomas R. Hansen; Air Pros Ma, LLC; Michael Hansen; And Paul Neary

CourtMassachusetts Superior Court
DecidedApril 29, 2026
Docket2484CV00083-BLS2
StatusPublished

This text of Gem Plumbing and Heating Services, LLC v. Rusty's, Inc; Michael J. Roderick; Thomas R. Hansen; Air Pros Ma, LLC; Michael Hansen; And Paul Neary (Gem Plumbing and Heating Services, LLC v. Rusty's, Inc; Michael J. Roderick; Thomas R. Hansen; Air Pros Ma, LLC; Michael Hansen; And Paul Neary) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gem Plumbing and Heating Services, LLC v. Rusty's, Inc; Michael J. Roderick; Thomas R. Hansen; Air Pros Ma, LLC; Michael Hansen; And Paul Neary, (Mass. Ct. App. 2026).

Opinion

Gem Plumbing and Heating Services, LLC, bought a similar business called Rusty’s, Inc., from Michael Roderick and Thomas Hansen. Two weeks after the closing Gem fired Roderick and Hansen, claiming that they knew but did not disclose that their employees Michael Hansen (the son of Tom Hansen) and Paul Neary were running a competing HVAC business called Air Pros MA, LLC. This lawsuit followed.

Gem claims that the Rusty’s Defendants (Rusty’s, Roderick, and Tom Hansen) were required but failed to disclose that Air Pros was competing with Rusty’s and that they thereby committed fraud, breached the parties’ Asset Purchase Agreement (the “APA”), committed an unfair or deceptive trade practice in violation of G.L. c. 93A, and engaged in civil conspiracy. It also claims that Roderick and Hansen thereby breached their fiduciary duties after becoming Gem employees. The Rusty’s Defendants assert a number of counterclaims.

The Rusty’s Defendants have moved for summary judgment on Gem’s remaining claims against them and on their counterclaims. Gem settled and has dismissed its claims against the other three defendants.

The summary judgment record establishes that the Rusty’s Defendants are entitled to judgment in their favor as a matter of law on all of Gem’s remaining claims against them. Roderick and Hansen are entitled to partial summary judgment as to liability on their counterclaim for breach of their employment agreements. Gem is entitled to summary judgment in its favor under Mass. R. Civ. P. 56(c) with respect to the Wage Act counterclaim. The Court will otherwise deny the summary judgment motion and will deny the related motion to strike as moot.

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1. Gem’s Remaining Claims cannot survive summary judgment because Gem has been unable to muster evidence sufficient to prove key elements of those claims. See Kourouvacilis v. General Motors Corp., 410 Mass. 706, 715–716 (1991). “A nonmoving party’s failure to establish an essential element of her claim ‘renders all other facts immaterial’ and mandates summary judgment in favor of the moving party.” Roman v. Trustees of Tufts College, 461 Mass. 707, 711 (2012), quoting Kourouvacilis, supra, at 711.

1.1. Fraud and Breach of Contract. The Rusty’s Defendants made a series of representations and warranties in § 5 of the APA. Gem’s claims for fraud and for breach of contract are based on allegations that four of the representations made by the Rusty’s Defendants in the APA were false. The summary judgment record shows that Gem cannot prove any part of these claims.

The Court finds that all relevant provisions of the APA are unambiguous when considering the contract as a whole, and that their meaning is therefore a question of law that the Court may decide on a summary judgment motion. See Seaco Ins. Co. v. Barbosa, 435 Mass. 772, 779 (2002); Trustees of Beechwood Village Condominium Trust v. USAlliance Federal Credit Union, 95 Mass. App. Ct. 278, 284–285 (2019). “Whether a contract is ambiguous is also a question of law.” Eigerman v. Putnam Investments, Inc., 450 Mass. 281, 287 (2007). Even if contract language is hard to parse, that does not make it ambiguous. See Sullivan v. Southland Life Ins. Co., 67 Mass. App. Ct. 439, 443 (2006). That the parties disagree about how to read the APA does not make it ambiguous either. “[A]mbiguity is not created simply because a controversy exists between parties, each favoring an interpretation contrary to the other’s.” Indus Partners, LLC v. Intelligroup, Inc., 77 Mass. App. Ct. 793, 795 (2010) (affirming summary judgment), quoting Suffolk Constr. Co., Inc. v. Lanco Scaffolding Co., 47 Mass. App. Ct. 726, 729 (1999).

1.1.1. Representation of No Affiliates. In § 5.E of the APA, the Rusty’s Defendants represented that Rusty’s “does not have any subsidiaries, other affiliates (other than the Owners and Landlord)[,] or investments in any other entity or business or operation.”

Gem cannot show that this statement was false, because it cannot establish that Air Pros was a subsidiary or affiliate of Rusty’s or that any of the Rusty’s Defendants had any investment in Air Pros. It is undisputed that none of the Rusty’s Defendants held any direct or indirect ownership interest in Air Pros or had any involvement in the operations of Air Pros.

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The APA does not define “affiliate.” But in the context of business contracts like this, the term “affiliate” refers to a “corporation that is related to another corporation by shareholdings or other means of control; a subsidiary, parent, or sibling corporation.” Lombardi Corp. v. Urban Improvement Fund Ltd. 1973, Suffolk Sup. Ct. no. 1484CV03922-BLS1, 2016 WL 3919624, at *12 (Mass. Super. May 20, 2016) (Kaplan, J.), quoting Black’s Law Dict. (10th ed. 2014); accord, e.g., Delaware Ins. Guar. Ass'n v. Christiana Care Health Servs., Inc., 892 A.2d 1073, 1077 (Del. 2006); Satterfield v. Simon & Shuster, Inc., 569 F.3d 946, 955 (9th Cir. 2009).

In turn, “control” means “[t]he direct or indirect power to govern the management and policies of a person or entity, whether through ownership of voting securities, by contract, or otherwise; the power or authority to manage, direct, or oversee.” Planned Parenthood Fed'n of Am., Inc. v. Kennedy, 162 F.4th 155, 172 (1st Cir. 2025), quoting Black’s Law Dictionary (12th ed. 2024); accord, e.g., Rothstein v. American Int’l Group, Inc., 837 F.3d 195, 206 (2d Cir. 2016); Lombardo’s Ravioli Kitchen, Inc. v. Ryan, 842 A.2d 1038, 1096 (Conn. 2004).

Merely showing that someone has ability “to influence managerial decisions” does not establish their control over a corporation, because influence is not the same as having “the power to direct or cause the direction of the management and policies” of the corporation. See, e.g., In re Weight Watchers International Inc. Securities Litig., 504 F.Supp.3d 224, 263 (S.D.N.Y. 2020), quoting In re BioScrip, Inc. Sec. Litig., 95 F.Supp. 3d 711, 740 (S.D.N.Y. 2015) (power to influence) and S.E.C. V. First Jersey Sec., Inc., 101 F.3d 1450, 1472–1473 (2d Cir. 1996) (power to direct management and policies).

Gem cannot show that Air Pros was an affiliate of Rusty’s because it has mustered no evidence that any of the Rusty’s Defendants owned any part of Air Pros or otherwise had the power to direct Air Pros’ management and policies.

That two of Rusty’s employees, Mike Hansen and Paul Neary, owned Air Pros does not make that entity an “affiliate” of Rusty’s. It is undisputed that Mike Hansen and Neary did not have any ownership interest in Rusty’s; as Gem concedes, Mike Hansen released any claimed ownership interest before the APA was executed. Though Mike Hansen’s master plumber’s license was used by Rusty’s that did not make him a Rusty’s shareholder. In sum, the summary judgment record shows it is undisputed that Mike Hansen and Neary had no

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control over Rusty’s, and thus their ownership of Air Pros did not make the two companies affiliates.

The argument by Gem that Rusty’s effectively controlled Air Pros because Mike Hansen and Paul Neary were subject to non-competition agreements is without merit. Two corporations are considered to be affiliates only if common owners have the power to control the management and policies of both entities.

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Gem Plumbing and Heating Services, LLC v. Rusty's, Inc; Michael J. Roderick; Thomas R. Hansen; Air Pros Ma, LLC; Michael Hansen; And Paul Neary, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gem-plumbing-and-heating-services-llc-v-rustys-inc-michael-j-masssuperct-2026.