essential elements claim (Massachusetts) · Go Syfert
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essential elements claim in Massachusetts

23 Massachusetts opinions name it 4 courts 1991–2025 2 in the last five years

The cases below were cited by Massachusetts courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (18)

CaseFollowedCited
Kourouvacilis v. General Motors Corp.green
mass · 1991 · cited in 8 Massachusetts opinions naming this issue, 1997–2012
2 sentences

2012Kourouvacilis v. General Motors Corp., 410 Mass. 706, 716 (1991). 1.

2006See Kourouvacilis, 410 Mass. at 711-12 .

88
Smith v. Hillgreen
mass · 1919 · cited in 2 Massachusetts opinions naming this issue, 2011–2025
2 sentences

2025See, e.g., Frontier Enters., Inc. v. Anchor Co. of Marblehead, Inc., 404 Mass. 506, 513 (1989); Smith v. Hill, 232 Mass. 188, 190 (1919).

2011See, e.g., Powers v. Russell, 13 Pick. 69 , 76 (1832); Smith v. Hill, 232 Mass. 188, 190 (1919); Frontier Enterprises, Inc. v. Anchor Co. of Marblehead, Inc., 404 Mass. 506, 513 (1989).

22
Frontier Enterprises, Inc. v. Anchor Co. of Marbleheadgreen
mass · 1989 · cited in 2 Massachusetts opinions naming this issue, 2011–2025
2 sentences

2025See, e.g., Frontier Enters., Inc. v. Anchor Co. of Marblehead, Inc., 404 Mass. 506, 513 (1989); Smith v. Hill, 232 Mass. 188, 190 (1919).

2011See, e.g., Powers v. Russell, 13 Pick. 69 , 76 (1832); Smith v. Hill, 232 Mass. 188, 190 (1919); Frontier Enterprises, Inc. v. Anchor Co. of Marblehead, Inc., 404 Mass. 506, 513 (1989).

22
Aunyx Corporation v. Canon U.S.A., Incorporatedgreen
ca1 · 1992 · cited in 2 Massachusetts opinions naming this issue, 2004–2004
2 sentences

2004The essential elements of claim preclusion are “(1) a final judgment on the merits in [the first] action; (2) an identity of parties or privies in the two suits; and (3) an identity of the cause of action in both the earher and later suits.” Aunyx Corp. v. Canon U.S.A, Inc., 978 F.2d 3, 6 (1st Cir. 1992), cert, denied, 507 U.S. 973 (1993).

2004“The essential elements of claim preclusion are: ‘(1) a final judgment on the merits in [the first] action; (2) an identity of parties or privies in the two suits; and (3) an identity of the cause of action in both the earlier and later suits.’ ” 4 Mancuso v. Kinchla, 60 Mass. App. Ct. 558, 567 (2004), quoting from Aunyx Corp. v. Canon U.S.A., Inc., 978 F.2d 3, 6 (1st Cir. 1992), cert. denied, 507 U.S. 973 (1993).

22
Whitehall Co. v. Merrimack Valley Distributing Co.green
massappct · 2002 · cited in 1 Massachusetts opinions naming this issue, 2025–2025
1 sentence

2025Co., 56 Mass. App. Ct. 853 , 856–857 (2002) ("the complaint must put the adversary on notice of the essential elements of the claim the pleader intends to assert").

11
Conley v. Romerigreen
massappct · 2004 · cited in 1 Massachusetts opinions naming this issue, 2010–2010
1 sentence

2010The essential elements of a claim for negligent infliction of emotional distress are “(1) negligence; (2) emotional distress; (3) causation; (4) physical harm manifested by objective symptomatology; and (5) that a reasonable person would have suffered emotional distress under the circumstances of the case.” Conley v. Romeri, 60 Mass.App.Ct. 799, 801 (2004), quoting Payton v. Abbott Labs, 386 Mass. 540, 557 (1982).

11
Payton v. Abbott Labsgreen
mass · 1982 · cited in 1 Massachusetts opinions naming this issue, 2010–2010
1 sentence

2010The essential elements of a claim for negligent infliction of emotional distress are “(1) negligence; (2) emotional distress; (3) causation; (4) physical harm manifested by objective symptomatology; and (5) that a reasonable person would have suffered emotional distress under the circumstances of the case.” Conley v. Romeri, 60 Mass.App.Ct. 799, 801 (2004), quoting Payton v. Abbott Labs, 386 Mass. 540, 557 (1982).

11
Davis v. Westwood Groupgreen
mass · 1995 · cited in 1 Massachusetts opinions naming this issue, 2007–2007
1 sentence

2007“If a person voluntarily assumes a duty or undertakes to render services to another that should have been seen necessary for her protection, that person may be liable for harm caused because of the negligent performance of his undertaking.” Davis v. Westwood Group, 420 Mass. 739, 746 (1995), quoting Thorson v. Mandell 402 Mass. 744, 748 (1988).

11
Thorson v. Mandellgreen
mass · 1988 · cited in 1 Massachusetts opinions naming this issue, 2007–2007
1 sentence

2007“If a person voluntarily assumes a duty or undertakes to render services to another that should have been seen necessary for her protection, that person may be liable for harm caused because of the negligent performance of his undertaking.” Davis v. Westwood Group, 420 Mass. 739, 746 (1995), quoting Thorson v. Mandell 402 Mass. 744, 748 (1988).

11
Tetrault v. Mahoneygreen
mass · 1997 · cited in 1 Massachusetts opinions naming this issue, 2006–2006
1 sentence

2006A claim of undue influence requires proof that “(1) [an] unnatural disposition has been made (2) by a person susceptible to undue influence to the advantage of someone (3) with an opportunity to exercise undue influence and (4) who in fact has used that opportunity to procure the contested disposition through improper means.” Tetrault v. Mahoney, Hawkes & Goldings, 425 Mass. 456, 464 (1997), citing Heinrich v. Silvernail, 23 Mass. App. Ct. 218, 223 (1986).

11
Heinrich v. Silvernailgreen
massappct · 1986 · cited in 1 Massachusetts opinions naming this issue, 2006–2006
1 sentence

2006A claim of undue influence requires proof that “(1) [an] unnatural disposition has been made (2) by a person susceptible to undue influence to the advantage of someone (3) with an opportunity to exercise undue influence and (4) who in fact has used that opportunity to procure the contested disposition through improper means.” Tetrault v. Mahoney, Hawkes & Goldings, 425 Mass. 456, 464 (1997), citing Heinrich v. Silvernail, 23 Mass. App. Ct. 218, 223 (1986).

11
Mancuso v. Kinchlagreen
massappct · 2004 · cited in 1 Massachusetts opinions naming this issue, 2004–2004
1 sentence

2004“The essential elements of claim preclusion are: ‘(1) a final judgment on the merits in [the first] action; (2) an identity of parties or privies in the two suits; and (3) an identity of the cause of action in both the earlier and later suits.’ ” 4 Mancuso v. Kinchla, 60 Mass. App. Ct. 558, 567 (2004), quoting from Aunyx Corp. v. Canon U.S.A., Inc., 978 F.2d 3, 6 (1st Cir. 1992), cert. denied, 507 U.S. 973 (1993).

11
Schaer v. Brandeis Universitygreen
mass · 2000 · cited in 1 Massachusetts opinions naming this issue, 2002–2002
1 sentence

2002It is not enough that a viable claim lurks somewhere in “conclusory descriptions of a ‘general scenario which could be dominated by unpleaded facts.’ ” Schaer v. Brandeis Univ., 432 Mass. 474, 478 (2000), quoting from Judge v. Lowell, 160 F.3d 67, 77 (1st Cir. 1998).

11
Rebecca Judge v. City of Lowellgreen
ca1 · 1998 · cited in 1 Massachusetts opinions naming this issue, 2002–2002
1 sentence

2002It is not enough that a viable claim lurks somewhere in “conclusory descriptions of a ‘general scenario which could be dominated by unpleaded facts.’ ” Schaer v. Brandeis Univ., 432 Mass. 474, 478 (2000), quoting from Judge v. Lowell, 160 F.3d 67, 77 (1st Cir. 1998).

11
Poly v. Moylangreen
mass · 1996 · cited in 1 Massachusetts opinions naming this issue, 1998–1998
1 sentence

1998Indeed, a set of facts which may result in a valid claim under the common law may, nevertheless, fail to rise to the level of a violation of the c. 93A Poly v. Moylan, 423 Mass. 141, 151 (1996) (judge may make independent, different findings on c. 93A aspect of case where facts gave rise to parallel common law claims).

11
Wilson v. Honeywell, Inc.green
mass · 1991 · cited in 1 Massachusetts opinions naming this issue, 1991–1991
2 sentences

1991See Stapleton v. Macchi, 401 Mass. 725, 728 (1988). [1] Although we indulge every inference to his advantage, Wilson v. Honeywell, Inc., 409 Mass. 803, 804 (1991), the plaintiff is nonetheless required to establish the essential elements of his claim "either by direct evidence or rational inference of probabilities from established facts." *92 Zezuski v. Jenny Mfg.

1991See Stapleton v. Macchi, 401 Mass. 725, 728 (1988). 1 Although we indulge every inference to his advantage, Wilson v. Honeywell, Inc., 409 Mass. 803, 804 (1991), the plaintiff is nonetheless required to establish the essential elements of his claim “either by direct evidence or rational inference of probabilities from established facts.” Zezuski v. Jenny Mfg.

11
Zezuski v. Jenny Manufacturing Co.green
mass · 1973 · cited in 1 Massachusetts opinions naming this issue, 1991–1991
2 sentences

1991Co., 363 Mass. 324, 329 (1973), quoting Bigwood, supra .

1991Co., 363 Mass. 324, 329 (1973), quoting Bigwood, supra. Inferences drawn from the evidence must be based on probabilities, not possibilities.

11
Stapleton v. MacChigreen
mass · 1988 · cited in 1 Massachusetts opinions naming this issue, 1991–1991
2 sentences

1991See Stapleton v. Macchi, 401 Mass. 725, 728 (1988). [1] Although we indulge every inference to his advantage, Wilson v. Honeywell, Inc., 409 Mass. 803, 804 (1991), the plaintiff is nonetheless required to establish the essential elements of his claim "either by direct evidence or rational inference of probabilities from established facts." *92 Zezuski v. Jenny Mfg.

1991See Stapleton v. Macchi, 401 Mass. 725, 728 (1988). 1 Although we indulge every inference to his advantage, Wilson v. Honeywell, Inc., 409 Mass. 803, 804 (1991), the plaintiff is nonetheless required to establish the essential elements of his claim “either by direct evidence or rational inference of probabilities from established facts.” Zezuski v. Jenny Mfg.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
Ashley v. Epic Divers, Inc. green
scotus · 1993
2 sentences

2004The essential elements of claim preclusion are “(1) a final judgment on the merits in [the first] action; (2) an identity of parties or privies in the two suits; and (3) an identity of the cause of action in both the earher and later suits.” Aunyx Corp. v. Canon U.S.A, Inc., 978 F.2d 3, 6 (1st Cir. 1992), cert, denied, 507 U.S. 973 (1993).

2004“The essential elements of claim preclusion are: ‘(1) a final judgment on the merits in [the first] action; (2) an identity of parties or privies in the two suits; and (3) an identity of the cause of action in both the earlier and later suits.’ ” 4 Mancuso v. Kinchla, 60 Mass. App. Ct. 558, 567 (2004), quoting from Aunyx Corp. v. Canon U.S.A., Inc., 978 F.2d 3, 6 (1st Cir. 1992), cert. denied, 507 U.S. 973 (1993).

22004–2004
Atlas Tack Corp. v. Donabed green
massappct · 1999
1 sentence

2018The essential elements of a claim for legal malpractice are that the "attorney committed a breach of the duty to use reasonable care," "the plaintiff suffered actual loss," and "the attorney's negligence proximately caused such loss." Atlas Tack Corp . v. Donabed , 47 Mass. App. Ct. 221 , 226 (1999).

12018–2018
Benson v. Massachusetts General Hospital green
massappct · 2000
1 sentence

2018Benson , supra at 533 .

12018–2018
Flesner v. Technical Communications Corp. green
mass · 1991
1 sentence

2014Id. at 817 .

12014–2014
Missett v. Cardinal Cushing High School green
massappct · 1997
1 sentence

1999Missett v. Cardinal Cushing High Sch., 43 Mass. App. Ct. 5 , 6 n.3 (1997), citing Mass. R.A.P. 16(a)(4), as amended, 367 Mass. 921 (1975).

11999–1999
Bigwood v. Boston & Northern Street Railway Co. green
· 1911
2 sentences

1991Co., 363 Mass. 324, 329 (1973), quoting Bigwood, supra .

1991Co., 363 Mass. 324, 329 (1973), quoting Bigwood, supra. Inferences drawn from the evidence must be based on probabilities, not possibilities.

11991–1991

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 93A, § 2 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

OH 192 (1978–2025) TX 143 (1937–2024) TN 107 (1976–2024) WA 101 (1961–2026) ID 70 (1955–2026) LA 53 (1938–2022) GA 50 (1935–2024) NC 48 (1978–2025) WY 44 (1979–2020) NY 42 (1894–2025) CA 42 (1920–2026) NM 31 (1971–2025) IL 31 (1971–2026) FL 30 (1942–2026) CT 28 (1963–2019) MO 26 (1957–2016) IN 25 (1972–2026) MS 24 (1995–2025) MA 23 (1991–2025) HI 20 (1995–2026) OR 19 (1984–2025) AL 18 (1923–2024) PA 17 (1926–2024) OK 16 (1911–2021) WV 14 (1987–2025) KY 13 (1949–2026) KS 12 (1953–2021) VA 12 (1988–2025) IA 11 (1935–2026) ME 10 (2011–2023) MI 10 (2014–2026) MD 9 (1923–2010) VT 8 (2003–2026) NJ 8 (1979–2025) ND 6 (1978–1996) DC 6 (1979–2003) AZ 6 (1936–1983) MN 5 (1972–2016) UT 5 (1994–2023) RI 5 (1987–2006) SC 4 (1932–2000) MT 4 (1989–2022) CO 3 (1988–2025) SD 3 (1992–2002) AK 3 (1991–2014) AR 3 (1998–2010)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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