New England Auto Max, Inc. v. Hanley

CourtMassachusetts Supreme Judicial Court
DecidedMay 20, 2024
DocketSJC 13419
StatusPublished

This text of New England Auto Max, Inc. v. Hanley (New England Auto Max, Inc. v. Hanley) is published on Counsel Stack Legal Research, covering Massachusetts Supreme Judicial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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New England Auto Max, Inc. v. Hanley, (Mass. 2024).

Opinion

NOTICE: All slip opinions and orders are subject to formal revision and are superseded by the advance sheets and bound volumes of the Official Reports. If you find a typographical error or other formal error, please notify the Reporter of Decisions, Supreme Judicial Court, John Adams Courthouse, 1 Pemberton Square, Suite 2500, Boston, MA, 02108-1750; (617) 557- 1030; SJCReporter@sjc.state.ma.us

SJC-13419

NEW ENGLAND AUTO MAX, INC., & others1 vs. MICHAEL HANLEY2 & others.3

Suffolk. February 5, 2024. - May 20, 2024.

Present: Budd, C.J., Gaziano, Kafker, Wendlandt, & Dewar, JJ.

Supreme Judicial Court, Superintendence of inferior courts. District Court, Jurisdiction, Appellate Division. Practice, Civil, Damages, Interlocutory appeal, Appellate Division: appeal, Motion to dismiss. Damages. Statute, Construction.

Civil action commenced in the Supreme Judicial Court for the county of Suffolk on January 19, 2023.

The case was heard by Georges, J.

Mark A. Aronsson (William A. Raven also present) for the petitioners. Robert Richardson (Edward C. Cumbo also present) for Michael Hanley & another.

1 New England AutoMax, Inc.; and Howard Wilner.

2 Individually and on behalf of all others similarly situated.

3 Christopher Trombley, individually and on behalf of all others similarly situated; and Quincy Division of the District Court Department, as a nominal party. 2

DEWAR, J. A civil case may proceed to trial in the

District Court or Boston Municipal Court only if there is no

reasonable likelihood that recovery by the plaintiff will exceed

$50,000, on penalty of dismissal without prejudice to refiling

in the Superior Court. G. L. c. 218, §§ 19, 19A (b). The

petitioners, who are defendants in the underlying civil action,

unsuccessfully moved to dismiss that action for exceeding the

$50,000 limit.4 They then petitioned this court for

extraordinary relief under G. L. c. 211, § 3. A single justice

denied relief on the ground that the defendants had an alternate

avenue of appellate relief, and we allowed the defendants'

appeal from that decision to proceed.

Today we conclude that the single justice did not err or

abuse his discretion in denying relief to these defendants, but

we exercise our discretion to decide the question of law they

present. We hold that, under G. L. c. 231, § 108, these

defendants had a right to an interlocutory appeal to the

Appellate Division of the District Court (Appellate Division) on

the question of law they press before this court -- an alternate

avenue of appellate review that would ordinarily preclude relief

4 For ease of reference, we refer to the petitioners and respondents by their status as defendants and plaintiffs in the underlying action. 3

under G. L. c. 211, § 3. We recognize, however, that the

question of law the defendants raise relates to the

administration of justice in our trial courts, and we exercise

our general superintendence power to address it. We conclude

that the District Court judge erred in holding that G. L.

c. 218, § 19A, constrains a court from looking beyond a

plaintiff's initial statement of damages in assessing whether

there is a reasonable likelihood that recovery by the plaintiff

will exceed $50,000. Rather, the statute requires the court to

consider the nature of the action itself -- and thus the

complaint then before the court. We therefore remand the case

to the county court for entry of an order vacating the denial of

the defendants' motion to dismiss and remanding to the District

Court for further proceedings consistent with today's opinion.

1. Background. a. Statutory scheme. In 2004, the

Legislature enacted the current versions of G. L. c. 218, §§ 19

and 19A, to establish a Statewide "one trial" system for civil

cases and simplify the allocation of cases between the Superior

Court and the District and Boston Municipal Courts. See

St. 2004, c. 252, §§ 5, 6; Sperounes v. Farese, 449 Mass. 800,

802-803 (2007). General Laws c. 218, § 19, vests the District

and Boston Municipal Courts with original jurisdiction over

civil actions for money damages. The statute further provides,

however, that actions for money damages "may proceed" in these 4

courts rather than in Superior Court "only if there is no

reasonable likelihood that recovery by the plaintiff will exceed

[$50,000]."5 Id. The statute specifies that, "[w]here multiple

damages are allowed by law, the amount of single damages claimed

shall control." Id.

General Laws c. 218, § 19A, prescribes the procedures for

implementing this nonjurisdictional $50,000 limit. See

Sperounes, 449 Mass. at 801. Most relevant here, a plaintiff,

upon commencing an action for money damages, must submit a

statement of damages estimating the plaintiff's potential

damages if the plaintiff prevails. See G. L. c. 218, § 19A (a).

The defendant is entitled to file a competing statement of

damages with the defendant's answer. Id. The statute then sets

forth the circumstances in which a judge may dismiss a

plaintiff's action for failure to comply with the $50,000 limit,

the details of which we reserve for our discussion below.

If a judge does dismiss a plaintiff's action under this

provision, the plaintiff may recommence the action in the

appropriate court within thirty days, with the filing fee

reduced by the amount the plaintiff initially paid. G. L.

c. 218, §§ 19A (b), (d). A plaintiff may also appeal from the

5 The statutory limit increased from $25,000 to $50,000 in 2020 under the governing standing order. See Supreme Judicial Court, Order Regarding Amount-in-Controversy Requirement Under G. L. c. 218, § 19, and G. L. c. 212, § 3 (July 17, 2019). 5

dismissal to a single justice of the Appeals Court, and the

single justice's decision "shall be final." G. L. c. 218,

§ 19A (c). The statute expressly forecloses "any post-judgment

relief in any case" based on "[v]iolation of the requirements

for proceeding in the district court or Boston municipal court

departments." G. L. c. 218, § 19A (b).

b. Prior proceedings. The underlying action arises out of

the plaintiffs' alleged employment at the automobile dealership

business operated by the defendants, New England Auto Max, Inc.,

New England AutoMax, Inc., and Howard Wilner. On June 14, 2022,

plaintiff Michael Hanley filed a putative class action complaint

in the District Court, alleging that the defendants unlawfully

deducted employees' "regular pay" from their future earned

commissions and bonuses in violation of G. L. c. 151, § 1, and

G. L. c. 149, §§ 148 and 150. Hanley, who alleged he had worked

for the defendants' business from approximately 2015 to 2020,

also brought the action on behalf of a proposed class of

employees who had worked for the defendants for all or part of

the three-year period preceding the filing of the complaint. On

behalf of himself and the class, he sought to recover damages

under G. L. c. 149, § 150. At the time of filing, Hanley

submitted a statement of damages pursuant to G. L. c. 218,

§ 19A, estimating that single damages for the claim brought on 6

his own behalf would amount to "more than $25,000," but were

reasonably likely to be "less than $50,000."

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