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Day v. Kerkorian

Citations: 72 Mass. App. Ct. 1; 887 N.E.2d 1098; 2008 Mass. App. LEXIS 590Docket: No. 07-P-174

Court: Massachusetts Appeals Court; June 6, 2008; Massachusetts; State Appellate Court

Narrative Opinion Summary

The case involves a dispute between a plaintiff and an insurance agent concerning alleged interference with a contractual relationship and violations of unfair practices under G. L. c. 93A. The plaintiff had purchased disability insurance policies and later discovered issues with his coverage related to a cancellation notation made by the agent. The insurance company denied coverage under one of the policies, leading the plaintiff to file a lawsuit. The agent moved for summary judgment, asserting that the statute of limitations had expired, the statements were protected by litigation privilege, and the plaintiff could not prove damages. The Superior Court agreed with the statute of limitations defense and dismissed the interference claim, but the G. L. c. 93A claim was remanded for further proceedings. The court found that the plaintiff's awareness of the denial was enough to start the limitations period, and issues regarding litigation privilege and damages remained unresolved. The plaintiff's earlier naming of the insurance company as a defendant was settled, and a previous dismissal based on claim preclusion was overturned, allowing the case to proceed. The outcome included maintaining the dismissal of the interference claim while allowing the unfair practices claim to continue in court.

Legal Issues Addressed

Accrual of Claims and the Discovery Rule

Application: Day's knowledge of the denial of his claim under the second policy triggered the statute's accrual, notwithstanding his uncertainty about the extent of damages.

Reasoning: By that time, Day had sufficient knowledge regarding the alleged harm to trigger the statute's accrual.

G. L. c. 93A Claims and Timeliness

Application: The court found no issue with the timeliness of G. L. c. 93A claims, which have a four-year statute of limitations.

Reasoning: For the G. L. c. 93A claims, which have a four-year statute of limitations, there was no issue of untimeliness.

Impact of Claim Preclusion and Settlement

Application: The court ruled that a previous dismissal based on claim preclusion was reversed, allowing for further proceedings and impacting the claim for attorney’s fees.

Reasoning: Earlier, another judge dismissed Day's complaint based on claim preclusion; however, this dismissal was reversed, allowing for further proceedings.

Litigation Privilege in Defense Preparation

Application: The applicability of litigation privilege for Kerkorian's statements was considered uncertain, especially given ongoing criminal investigations.

Reasoning: The applicability of 'litigation privilege' in this case is uncertain, as it traditionally serves as a defense against defamation claims for statements made by witnesses during judicial proceedings.

Statute of Limitations under G. L. c. 260

Application: The court applied the three-year statute of limitations to the interference claim, concluding it expired before the complaint was filed.

Reasoning: The Superior Court granted summary judgment in favor of Kerkorian on the interference claim, which was subject to a three-year statute of limitations under G. L. c. 260.

Summary Judgment and Material Factual Issues

Application: The court found that Kerkorian's claim regarding Day's inability to prove damages was unsupported, as there were material factual issues.

Reasoning: The record does not support Kerkorian's claim that Day cannot prove damages at trial.