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Arrow Paper Corp. v. Boylston Foods, Inc.

Citations: 1 Mass. App. Ct. 808; 294 N.E.2d 472; 1973 Mass. App. LEXIS 537

Court: Massachusetts Appeals Court; March 1, 1973; Massachusetts; State Appellate Court

Narrative Opinion Summary

In a contract dispute adjudicated in the Municipal Court of Boston, the trial judge rendered a verdict in favor of the defendant. The plaintiff failed to request any legal rulings during the trial, which restricted their ability to appeal based on legal errors. Subsequently, the plaintiff's motion for a new trial, premised on alleged contradictions between the judge's decision and the evidence, was denied. The lack of formal requests for rulings of law further constrained the appellate review. The case was escalated to the Appellate Division, which dismissed the report; this decision was subsequently appealed under the Massachusetts General Laws, specifically G. L. c. 211. 4A and G. L. c. 211 A. 10 and 12. The appellate court affirmed the lower court's decision, emphasizing that the trial judge was under no obligation to issue legal rulings absent requests and that questions of law not presented at trial could not be considered on appeal. Additionally, the appellate court found no abuse of discretion in the trial court's denial of the new trial motion. Thus, the order dismissing the report was affirmed, maintaining the judgment for the defendant.

Legal Issues Addressed

Appeal under General Laws c. 211

Application: The procedural posture included an appeal under G. L. c. 211. 4A, and G. L. c. 211 A. 10 and 12, following the dismissal of the report by the Appellate Division.

Reasoning: The case was reported to the Appellate Division, which dismissed the report, leading to an appeal under G. L. c. 211. 4A, and G. L. c. 211 A. 10 and 12.

Appellate Review Limitations

Application: The appeal was constrained by the lack of legal questions raised during the trial, which limited the appellate court's ability to address these issues.

Reasoning: Questions of law not raised at trial cannot be addressed on appeal or in a new trial motion.

Discretion of the Trial Judge in Granting New Trials

Application: The court upheld that the decision to grant a new trial is at the discretion of the trial judge, and no abuse of discretion was identified in this case.

Reasoning: The determination of whether to grant a new trial lies within the judge's discretion, and no abuse of discretion was shown.

Requirement for Requests for Rulings of Law

Application: The court clarified that a trial judge is not required to make rulings of law in the absence of specific requests from the parties involved.

Reasoning: The plaintiff did not submit requests for rulings of law with the motion, which limited the scope for appeal.