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Industrial General v. Sequoia Pacific Systems

Citations: 849 F. Supp. 820; 1994 U.S. Dist. LEXIS 8794; 1994 WL 174753Docket: Civ. A. No. 89-2035-RGS

Court: District Court, D. Massachusetts; April 11, 1994; Federal District Court

Narrative Opinion Summary

The case concerns a contractual dispute between Industrial General Corporation's subsidiary, Plastek, and Sequoia Pacific Systems Corporation. The conflict arose from Sequoia's decision to replace its assembler, Moog Electronics, without notifying Plastek, leading to financial repercussions for Plastek following Moog's bankruptcy. Plastek claimed an oral contract existed with Sequoia, asserting Sequoia had promised to cover costs, but the jury found insufficient evidence of such a promise. Additionally, Plastek alleged a breach of the covenant of good faith and fair dealing, framed as a Chapter 93A claim, due to Sequoia's failure to disclose Moog's financial instability. The jury found Sequoia acted unfairly, awarding Plastek damages for unpaid invoices but denied multiple damages due to the nature of Sequoia's conduct. The court awarded reasonable attorney's fees for the Chapter 93A claim, excluding fees for the unsuccessful breach of contract claim. The judgment awarded Plastek $80,100.69 in damages with interest, reflecting the court's agreement with the jury's findings on unfair practices by Sequoia.

Legal Issues Addressed

Attorney's Fees and Apportionment in Chapter 93A Claims

Application: The court determined attorney's fees for successful Chapter 93A claims, excluding fees related to unsuccessful common law claims.

Reasoning: The trial judge, having reviewed the trial record and supporting documents, determined an objectively reasonable attorney's fee after considering the case's straightforward nature and the excessive legal fees requested by the plaintiff.

Breach of Contract and Oral Agreements

Application: The case examines whether an oral contract existed between Sequoia and Plastek, with Plastek alleging a promise by Sequoia to cover project costs.

Reasoning: Plastek's claim was based on an alleged oral contract with Sequoia, asserting a promise to cover costs for the entire project, supported by testimony from Plastek's President regarding a meeting with Sequoia's President.

Covenant of Good Faith and Fair Dealing

Application: Plastek alleged that Sequoia breached the covenant of good faith and fair dealing by not disclosing Moog's financial instability, which was framed as a Chapter 93A claim.

Reasoning: Additionally, Plastek alleged a breach of the covenant of good faith and fair dealing, framed as a Chapter 93A claim concerning unfair and deceptive practices by Sequoia.

Duty to Disclose in Fiduciary Relationships

Application: The court addressed whether Sequoia had a fiduciary duty to disclose Moog's financial instability, emphasizing that such duties arise in special relationships of trust.

Reasoning: The jury was instructed that a duty to disclose arises only in special relationships of trust, and that business transactions generally do not create such obligations.

Unfair or Deceptive Acts under Chapter 93A

Application: The jury found Sequoia acted unfairly by not informing Plastek about Moog's unreliability, aligning with standards under Chapter 93A.

Reasoning: The jury correctly found that Sequoia acted unfairly in not informing Plastek about Moog's unreliability and recognized that Plastek was in a position of trust and dependence regarding Sequoia.