The Nolan Group, LLC v. State Electric Corporation

CourtMassachusetts Superior Court
DecidedMarch 11, 2024
Docket2284CV00789-C
StatusPublished

This text of The Nolan Group, LLC v. State Electric Corporation (The Nolan Group, LLC v. State Electric Corporation) 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 Nolan Group, LLC v. State Electric Corporation, (Mass. Ct. App. 2024).

Opinion

SUPERIOR COURT

THE NOLAN GROUP, LLC v. STATE ELECTRIC CORPORATION

Docket: 2284CV00789-C
Dates: March 5, 2024
Present: Robert B. Gordon
County: SUFFOLK
Keywords: MEMORANDUM OF DECISION AND ORDER ON DEFENDANT’S MOTION FOR SUMMARY JUDGMENT

            This case arises out of a failed business relationship between Plaintiff The Nolan Group, LLC (“Plaintiff” or “TNG”) and Defendant State Electric Corporation (“Defendant” or “State Electric”). TNG has brought a four-count Complaint against State Electric, asserting claims for breach of contract, fraudulent misrepresentation, negligent misrepresentation, and unfair and deceptive trade practices under G.L. c. 93A, § 11. Following a nearly two-year period of active discovery, State Electric has moved for summary judgment on all counts of the Complaint. For the reasons which follow, Defendant’s motion shall be ALLOWED IN PART and DENIED IN PART.

RELEVANT FACTS[1]

            TNG is a consulting firm, State Electric an electrical contractor with which it did business between 2018 and 2021. The four-year window of the parties’ relationship can be

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[1] The following facts are drawn from the summary judgment record, as summarized in the parties’ jointly filed Superior Court Rule 9A(b)(5) Statement. The evidence is construed in the light most favorable to TNG, the non- movant, with all conflicts resolved in its favor for purposes of the Rule 56 motion only. See Bulwer v. Mt. Auburn Hosp., 473 Mass. 672, 680 (2016).

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divided into two distinct periods: (1) June, 2018 – March, 2020 (the “First Contract”) and (2) March, 2021 – September, 2021 (the “Second Contract”). Both periods are implicated in the present lawsuit.

            In the First Contract, representatives of TNG and State Electric negotiated a 12-month agreement (renewable annually), whereby TNG would perform unspecified services in which it leveraged its business relationships to help State Electric pitch prospective clients and thereby win compensated project work. Thus, in or around June of 2018, TNG and State Electric entered into a contract[2] in which State Electric agreed to pay a monthly retainer of $10,000 and production fees equal to 3% of all contract amounts State Electric earned from project work TNG helped procure.[3]

            From June of 2018 until March of 2020, TNG worked to assist State Electric in securing electrical contract projects from prospective clients such as Eversource, Encore, Gilbane and Stantec. In return, State Electric made all due monthly retainer payments of $10,000, but paid no percentage fees of any kind in respect of the new contractual project work it obtained.

            On or around March 23, 2020, State Electric notified TNG that a business slowdown caused by the Covid-19 pandemic required it to suspend its consulting arrangement with TNG. State Electric expressed the hope that this suspension would be short-lived and that the parties would be back working together soon. The record stands unrefuted that State Electric fully paid its $10,000 monthly retainer to TNG from June, 2018 through March, 2020, that TNG never

[2] TNG’s chief executive, Gregg Nolan, maintains that the parties memorialized their agreement in a signed writing that he personally witnessed. But despite diligent efforts throughout an extended period of discovery, no such mutually executed writing has been located by either side.

[3] The Court recognizes that the compensation terms of the parties’ contract are matters of substantial dispute and conflict in the evidence. The percentage fee hereinabove described is emphatically denied by the Defendant, but represents the most generous construction of the record evidence in favor of the Plaintiff’s claim, as Rule 56 requires.

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demanded additional fees in connection with its work during this time period, and that State Electric was entirely within its rights to suspend the parties’ contract at the time and in the manner it did.

            The Second Contract began with a meeting among the principals of TNG and State Electric on March 23, 2021, exactly one year to the day following the parties’ suspension of their First Contract. At this meeting, TNG chief executive Gregg Nolan expressed a desire for State Electric to re-engage his firm’s business services and resume the contractual relationship the pandemic had interrupted. According to Mr. Nolan, the meeting ended with an oral understanding and “handshake agreement” between himself and State Electric president Ronald Koning. The essence of the bargain was that TNG would resume its efforts to help State Electric secure new business projects, with a scope of work commensurate with TNG’s previous engagement. According to Mr. Nolan, the parties agreed that their contract would have neither a fixed durational term nor a monthly retainer. Instead, State Electric agreed to pay TNG a flat fee that would range between 8% and 12% of any newly contracted business, with the precise level of the percentage payment to be set from project to project.[4]

            The TNG/State Electric handshake agreement was never reduced to writing. Indeed, the record does not even reflect an attempt by these parties to do so. Following their March 23, 2021 meeting, however, TNG proceeded to assist State Electric in pitching its business to a series of four or five prospective clients. One such assisted pitch to The Richmond Group is alleged to

[4] Once again, the Court acknowledges that the putative “handshake agreement” alleged by TNG is a matter of substantial dispute. State Electric insists that the very imprecision in the compensation term now put forward by Plaintiff reflects a failure by the parties to reach a definite accord in 2021. In Mr. Koning’s telling, the handshake represented nothing more than the gestural civility with which businessmen customarily conclude meetings. That said, the Court is constrained by Rule 56 to credit the contrary (first-hand) account of Mr. Nolan, who testified to the effect that these parties did reach agreement on the essential terms of a renewed bargain. One expressed in terms of a 4% “range” regarding the per project fee, but a definite and fully concluded deal nonetheless.

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have resulted in an engagement known as “321 Harrison Avenue,” an electrical project that generated approximately $3.2 million in revenues to State Electric.[5]

            TNG thereafter pursued State Electric for fee compensation in connection with 321 Harrison Avenue for months, without success. In September, 2021, TNG transmitted a formal invoice to State Electric in the amount of $50,000, a fee it deemed “appropriate” based on consultation with others in the industry. State Electric never paid this invoice, or any other amount of money in respect of the parties’ Second Contract.

            At no time prior to the onset of this litigation did TNG ever make a demand on State Electric for purportedly due but unpaid amounts under the parties’ First Contract.

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Bluebook (online)
The Nolan Group, LLC v. State Electric Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-nolan-group-llc-v-state-electric-corporation-masssuperct-2024.