The First Liberty Insurance Corp. v. Rapid Flow, Inc.

CourtMassachusetts Superior Court
DecidedApril 10, 2024
Docket2384CV02142-C
StatusPublished

This text of The First Liberty Insurance Corp. v. Rapid Flow, Inc. (The First Liberty Insurance Corp. v. Rapid Flow, Inc.) 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
The First Liberty Insurance Corp. v. Rapid Flow, Inc., (Mass. Ct. App. 2024).

Opinion

SUPERIOR COURT

THE FIRST LIBERTY INSURANCE CORP. v. RAPID FLOW, INC.

Docket: 2384CV02142-C
Dates: April 4, 2024
Present: Robert B. Gordon
County: SUFFOLK
Keywords: MEMORANDUM OF DECISION AND ORDER ON PLAINTIFF,'S PARTIAL MOTION TO DISMISS COUNT II OF DEFENDANT'S COUNTERCLAIM

Presented for decision is Plaintiff The First Liberty Insurance Corp.'s Partial Motion to Dismiss Count II of Defendant's counterclaim. For the reasons which follow, the Plaintiffs motion shall be ALLOWED.

BACKGROUND

            Plaintiff The First Liberty Insurance Corp. ("First Liberty") has brought a breach of contract action against Rapid Flow, Inc. ("Rapid Flow"). By this action, First Liberty seeks to recover unpaid premiums purportedly due the carrier W1dcr a policy of commercial vehicle insurance issued to Rapid Flow. Rapid Flow contests the claimed indebtedness, and has asserted a counterclaim in which it charges that First Liberty engaged in "bad faith" in the manner in which it commenced its contract action. [1]

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[1] The precise legal grounds for the pleaded counterclaim are less than clear, but this is of no moment. Whether treated as a claim for unfair and deceptive business practices under G.L. c. 93A (as First Liberty has construed it), as

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The gravamen of Defendant’s counterclaim rests upon the fact that First Liberty previously attempted to commence its civil suit against Rapid Flow with an identical pleading (the "First Action") filed on January, 19, 2023. At that time, however, and for reasons not apparent in the Rule 12 record, Fir t Liberty failed to effect service of process on Rapid Flow within the 90-day period prescribed by Mass. R. Civ. P. 4(j). Several months after Rule 4(j)'s proof of service deadline passed, Jct having failed to seek an enlargement of time to make and demonstrate the required service, First Liberty purported to serve its Complaint in the First Action on Rapid Flow's president at his personal residence. Untimeliness aside, this was not effective service of process under Mass. R. Civ. P. 4(d)(2) (requiring service to be made upon a domestic corporation at its "princida1 place of business" within the Commonwealth).

            On August 30, 2023, and in accordance with Superior Court Rule 9A, Rapid Flow notified First Liberty of its intent to file a Motion to Dismiss pursuant to Mass. R. Civ. P. 12(b)(5) (insufficiency of service o process) and to seek legal fees in connection with same. Although Rapid Flow asserts to the Court that it "initiated a Rule 9C conference prior to filing its Motion to Dismiss," it is altogether evident that no actual 9C conference in fact occurred.[2]

a claim for common law abuse of process, or as a charge of bad faith filing entitling Rapid Flow to reasonable fees and costs under G.L. c. 231, § 6F, Defend t's allegations in Count II of its Counterclaim will simply  not give rise  to a viable cause of action against First Liberty.

[2] Had the aspirations of Superior Court Rule 9C been given any real consideration, Rapid Flaw's objections to the manner and timing of First Liberty's service of process could surely have been addressed and obviated without the need for motion filing. This is, of course, the very purpose of Rule 9C, viz.,to require lawyers to communicate with one another in a good faith attempt to eliminate or narrow areas of disagreement where possible, thereby reducing or even ending the need for judicial intervention. See Meschi v. Iverson, 60 Mass. App. Ct. 678,683 n.10 (2004) ("[T]he objective of Rule 9C [is] to encourage counsel to work out their differences ... before bringing them to court[.]"). Curable defects in service of process represent a textbook example of where a properly conducted Rule 9C conference will often spare the parties 1and the Court the burden of unnecessary, time-consuming and costly motion practice. In its unmistakable zeal to flog First Liberty for its service foot-faults, however, and seek legal foes for the cost of the flogging, Rapid Flow bypassed the expectations of Rule 9C. The irony that this Defendant now asserts a counterclaim for "bad faith" against First Liberty is not lost on the undersigned.

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            Shortly prior to the date when First Liberty's opposition to Rapid Flow's Motion to Dismiss would have been due for service, First Liberty unilaterally filed a motion for voluntary dismissal of the First Action in accordance with Mass. R. Civ. P. 4l(a)(l). This dismissal effectively mooted Rapid Flow's Motion to Dismiss, and thereby deprived Rapid Flow of the ability to seek as sanction an award of the legal fees it incurred in the preparation of such motion. Following the ensuing dismissal o1thc First Action on August 31, 2023, First Liberty commenced the present suit (identical in substance) on September 25, 2023. Rapid Flow has since counterclaimed, charging First Liberty with "bad faith" in its litigation practices. More specifically, the counterclaim alleges that First Liberty's supposed "misuse" of the Rule 41(a)(l) dismissal procedure to evade sanction-seeking in the First Action represents an act of bad faith, and breathes life into Rapid Flow's frustrated pursuit of such sanctions.

DISCUSSION

            The Court will not dwell o er-long on Rapid Plow's counterclaim, the meritlessness of which is manifest. A few points, however, are worth making, both to expound the Court's reasons for decision and to share guidance as to how and why this case has fallen so far off the rails.

            First, although Rapid Flow' motion papers persistently accuse First Liberty of a bad faith violation of Rule 4(j) in its voluntary dismissal of the First Action, there was in fact no such violation of this rule. Rule 4(j) merely states that, absent a demonstration of good cause why proper service could not be effected, failure to serve the summons and complaint within 90 days "shall" result in a dismissal of the action upon motion or at the Court's own initiative. Dismissal pursuant to Rule 4(j) is not a sanction for a bad faith filing, but instead an administrative disposition of a case that simply cannot proceed because the party-defendant has no proper

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notice of it. The entire premise of Rapid Plow's counterclaim, therefore, viz.,that First Liberty's failure to make timely service of the First Action under Rule 4 amounts to sanctionable bad faith, is misconceived.

            Second, where the presumptive time requirements for service under Rule 4 have not been satisfied by the plaintiff, a dismissal without prejudice is the prescribed remedy.  See Mass. R. Civ. P. 4G) (" ... shall be dismissed as to that defendant without prejudice" (emphasis added)). The awarding of legal fees to the party named in the action (but who, in the vast majority of cases, is not even aware of the suit because no service has been made) is plainly not contemplated. See Ventresca v. Town Manager of Billerica. 68 Mass. App. Ct.

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Related

In re Crossen
880 N.E.2d 352 (Massachusetts Supreme Judicial Court, 2008)
Shuman v. Stanley Works
571 N.E.2d 633 (Massachusetts Appeals Court, 1991)
Morgan v. Evans
657 N.E.2d 764 (Massachusetts Appeals Court, 1995)
Meschi v. Iverson
805 N.E.2d 72 (Massachusetts Appeals Court, 2004)
Ventresca v. Town Manager of Billerica
859 N.E.2d 897 (Massachusetts Appeals Court, 2007)

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The First Liberty Insurance Corp. v. Rapid Flow, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-first-liberty-insurance-corp-v-rapid-flow-inc-masssuperct-2024.