15 Massachusetts opinions name it 4 courts 1994–2015 0 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.
| Case | Followed | Cited |
|---|---|---|
Tatro v. Manor Care, Inc.green2 sentences2011See Tatro, 416 Mass. at 771 (construing §3(a)’s “arising from” language as broadly as “transacting business” language, and holding that “a claim arises from a defendant’s transaction of business in the forum State if the claim was made possible by, or lies in the wake of, the transaction of business in the forum State” (citation omitted)). 2007In Tatro, the Supreme Judicial Court held that the “arising from” language created a “but for” test, which meant that “a claim arises from a defendant’s transaction of business in the forum State if the claim was made possible by, or lies in the wake of, the transaction of business in the forum State.” Id., 770-71 . | 4 | 6 |
Joan Elena Lanier v. The American Board of Endodontics and the American Association of Endodontists, a Corporationgreen2 sentences1994In Lanier v. American Bd. of Endodontics, 843 F.2d 901 (6th Cir.), cert. denied, 488 U.S. 926 (1988), interpreting the Michigan long-arm statute, the United States Court of Appeals for the Sixth Circuit concluded that a claim arises from a defendant’s transaction of business in the forum State if the claim was made possible by, or lies in the wake of, the transaction of business in the forum State. 1994Adopting the language of Lanier v. American Bd. of Endodontics, 843 F.2d 901, 909 (6th Cir.), cert. denied, 488 U.S. 926 (1988), the court said “a claim arises from a defendant’s transaction of business in the forum State if the claim was made possible by, or lies in the wake of, the transaction of business in the forum State.” Tatro v. Manor Care, Inc., supra at 771. | 2 | 3 |
Connecticut National Bank v. Hoover Treated Wood Products, Inc.green2 sentences2002See also Conn. Nat’l Bank v. Hoover Treated Wood Products, Inc., 37 Mass.App.Ct. at 231, 234-35 (1994). 2001The Supreme Judicial Court has interpreted this language as establishing a “but for” test under which “a claim arises from a defendant’s transaction of business in the forum State if the claim was made possible by, or lies in the wake of, the transaction of business in the forum State.” See Tatro, 416 Mass. at 770-71; see also Conn. Nat’l Bank v. Hoover Treated Wood Products, Inc., 37 Mass.App.Ct. at 231, 234-35 (1954). | 2 | 2 |
State v. Mollicagreen1 sentence2010See State v. Bridges, supra at 202 (police consciously set out to evade law of forum); State v. Mollica, supra at 354-355 (motives of police relevant); State v. Cauley, supra. The law in this area is by no means clear or settled. | 1 | 1 |
State v. Bridgesred1 sentence2010See State v. Bridges, supra at 202 (police consciously set out to evade law of forum); State v. Mollica, supra at 354-355 (motives of police relevant); State v. Cauley, supra. The law in this area is by no means clear or settled. | 1 | 1 |
Santagate v. Towergreen1 sentence2009See Santagate v. Tower, 64 Mass.App.Ct. 324, 329 (2005) (“An equitable remedy for unjust enrichment is not available to a party with an adequate remedy at law”). | 1 | 1 |
Ross v. Rossgreen1 sentence2002Bd. of Endodontics, 843 F.2d 901, 909 (6th Cir.), cert. denied, 488 U.S. 926 (1988), interpreting the Michigan long-arm statute, and “applies to any purposeful acts by an individual, whether personal, private, or commercial.” Ross v. Ross, 371 Mass. 439, 441 (1976). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Middle South Utilities, Inc. v. Isquith
green
2 sentences1994In Lanier v. American Bd. of Endodontics, 843 F.2d 901 (6th Cir.), cert. denied, 488 U.S. 926 (1988), interpreting the Michigan long-arm statute, the United States Court of Appeals for the Sixth Circuit concluded that a claim arises from a defendant’s transaction of business in the forum State if the claim was made possible by, or lies in the wake of, the transaction of business in the forum State. 1994Adopting the language of Lanier v. American Bd. of Endodontics, 843 F.2d 901, 909 (6th Cir.), cert. denied, 488 U.S. 926 (1988), the court said “a claim arises from a defendant’s transaction of business in the forum State if the claim was made possible by, or lies in the wake of, the transaction of business in the forum State.” Tatro v. Manor Care, Inc., supra at 771. | 3 | 1994–2002 |
Commonwealth v. Jenkins
green
1 sentence2015Thus, “a claim arises from a defendant’s transaction of business in the forum State if the claim was made possible by, or lies in the wake of, the transaction of business in the forum State.” Id. | 1 | 2015–2015 |
State v. Cauley
green
1 sentence2010See State v. Bridges, supra at 202 (police consciously set out to evade law of forum); State v. Mollica, supra at 354-355 (motives of police relevant); State v. Cauley, supra. The law in this area is by no means clear or settled. | 1 | 2010–2010 |
The Bremen v. Zapata Off-Shore Co.
red
1 sentence2005The Bremen, 407 U.S. at 14 . | 1 | 2005–2005 |
New York & Massachusetts Motor Service, Inc. v. Massachusetts Commission Against Discrimination
green
1 sentence2004That the Legislature has provided complainants, and not respondents, the right to choose the forum in which their claim will be heard does not pose an equal protection problem. 19 This point was resolved by this court in New York & Mass. Motor Serv., Inc. v. Massachusetts Comm’n Against Discrimination, 401 Mass. 566 (1988). | 1 | 2004–2004 |
Dalis v. Buyer Advertising, Inc.
green
1 sentence2004It is true that the language of art. 15 “sweeps broadly.” Dalis, supra at 222 . | 1 | 2004–2004 |
Mary Jean Prejean v. Sonatrach, Inc.
green
1 sentence1994The fact that the claim sounds in tort and that the business transacted is contractual in character is not determinative, for “the contractual contact is a ‘but for’ causative factor for the tort since it brought the parties within tortious ‘striking distance’ of each other.” Id. at 770, quoting from Prejean v. Sonatrach, Inc., 652 F.2d 1260 , 1270 n.21 (5th Cir. 1981). | 1 | 1994–1994 |
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.
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.