breach of fiduciary duty claim (Massachusetts) · Go Syfert
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breach of fiduciary duty claim in Massachusetts

13 Massachusetts opinions name it 3 courts 1996–2026 1 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 (9)

CaseFollowedCited
Doe v. Harbor Schools, Inc.green
mass · 2006 · cited in 3 Massachusetts opinions naming this issue, 2010–2018
2 sentences

2010On a breach of fiduciary duty claim, the limitations period begins when the plaintiff has “ ‘actual knowledge’ that she has been injured by the fiduciary’s conduct.” Doe v. Harbor Schools, Inc., 446 Mass. at 254 , citing cases. “(T]he critical event that starts the limitations period running on a claim for breach of fiduciary duty is when the plaintiff first becomes aware of facts giving rise to her injury by the defendant, and not... when the plaintiff first understands the causal connection between her injuries and a legally cognizable claim against the defendant.” Id., at 248 .

2010On a breach of fiduciary duty claim, the limitations period begins when the plaintiff has “ ‘actual knowledge’ that she has been injured by the fiduciary’s conduct.” Doe v. Harbor Schools, Inc., 446 Mass. at 254 , citing cases. “(T]he critical event that starts the limitations period running on a claim for breach of fiduciary duty is when the plaintiff first becomes aware of facts giving rise to her injury by the defendant, and not... when the plaintiff first understands the causal connection between her injuries and a legally cognizable claim against the defendant.” Id., at 248 .

13
Cleary v. Clearygreen
mass · 1998 · cited in 1 Massachusetts opinions naming this issue, 2026–2026
1 sentence

2026The burden shifts if the fiduciary "benefits in a transaction with the person for whom he is a fiduciary." Cleary v. Cleary, 427 Mass. 286, 295 (1998).

11
Lattuca v. Robshamgreen
mass · 2004 · cited in 1 Massachusetts opinions naming this issue, 2018–2018
1 sentence

2018See Lattuca v. Robsham , 442 Mass. 205 , 213 (2004) ; Doe v. Harbor Sch., Inc ., 446 Mass. 245 , 254-257 (2006).

11
Wolfe v. Gormallygreen
mass · 2004 · cited in 1 Massachusetts opinions naming this issue, 2016–2016
1 sentence

2016See ibid.; Wolfe v. Gormally, 440 Mass. 699, 703-707 (2004).

11
Chokel v. Genzyme Corp.green
mass · 2007 · cited in 1 Massachusetts opinions naming this issue, 2010–2010
1 sentence

2010See Chokel v. Genzyme Corp., 449 Mass. 272, 278 (2007).

11
Fidelity Management & Research Co. v. Ostrandergreen
massappct · 1996 · cited in 1 Massachusetts opinions naming this issue, 2009–2009
1 sentence

2009See Amerada Hess Corp. v. Garabedian, 416 Mass. at 156 ; Fidelity Management & Research Co. v. Ostrander, 40 Mass.App.Ct. at 200 (equity requires that party seeking equitable relief have acted fairly and without fraud or deceit as to controversy in issue).

11
Amerada Hess Corp. v. Garabediangreen
mass · 1993 · cited in 1 Massachusetts opinions naming this issue, 2009–2009
1 sentence

2009See Amerada Hess Corp. v. Garabedian, 416 Mass. at 156 ; Fidelity Management & Research Co. v. Ostrander, 40 Mass.App.Ct. at 200 (equity requires that party seeking equitable relief have acted fairly and without fraud or deceit as to controversy in issue).

11
Gaw v. Sappettgreen
massappct · 2004 · cited in 1 Massachusetts opinions naming this issue, 2005–2005
1 sentence

2005When she issued her decision on the motion to amend, the trial judge was unaware of the then-recent decision of the Supreme Judicial Court in Krapf v. Krapf, 439 Mass. at 103 , in which the court explicitly stated that “[pjarties to a separation agreement stand jas fiduciaries to each other, and will be held to the highest standards of good faith and fair dealing in the performance of their contractual obligations.” See Gaw v. Sappett, 62 Mass. App. Ct. 405, 413 (2004).

11
Demoulas v. Demoulas Super Markets, Inc.green
mass · 1997 · cited in 1 Massachusetts opinions naming this issue, 2001–2001
1 sentence

2001Demoulas v. Demoulas Super Markets, Inc., 424 Mass. 501, 511 (1997).

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
Blanchette v. Blanchette green
mass · 1972
1 sentence

2026Burden of proof on the breach of fiduciary duty claim.4 Wright argues that the judge erred in not placing the burden of proof on Zantuhos because "he acted in a fiduciary capacity pursuant to the power of attorney," and therefore must prove that adding his name to the joint accounts was "neither the result of a violation of his obligations as a fiduciary nor the result of undue influence." Generally, "[t]he burden of proof is on the person seeking to show that the transaction is not to be taken at face value." Blanchette, 362 Mass. at 524 .

12026–2026
Riley v. Presnell green
mass · 1991
1 sentence

2006In Riley v. Presnell, 409 Mass. 239 (1991), for example, we addressed a breach of fiduciary duty claim centered on a therapeutic relationship.

12006–2006
Doe v. Harbor Schools, Inc. green
massappct · 2005
1 sentence

2006Instead of a constructive knowledge or objective reasonableness standard, the statute of limitations does not accrue on a fiduciary duty claim until the injured party “actually learns that the fiduciary has breached the trust.” Doe v. Harbor Sch., Inc 63 Mass.App.Ct. at 345 , further appellate review granted, 445 Mass. 1101 . 5 In explaining the test, the Appeals Court stated: [T]he relevant question is whether the plaintiff actually knew before [the alleged time of discovery], that [the defendant] was not just causing her psychological harm but was by his acts breaching the fiduciary obligati

12006–2006
Krapf v. Krapf green
mass · 2003
1 sentence

2005When she issued her decision on the motion to amend, the trial judge was unaware of the then-recent decision of the Supreme Judicial Court in Krapf v. Krapf, 439 Mass. at 103 , in which the court explicitly stated that “[pjarties to a separation agreement stand jas fiduciaries to each other, and will be held to the highest standards of good faith and fair dealing in the performance of their contractual obligations.” See Gaw v. Sappett, 62 Mass. App. Ct. 405, 413 (2004).

12005–2005
Wilkes v. Springside Nursing Home, Inc. green
mass · 1976
2 sentences

2003The Court held that even where there was no legitimate business purpose for the termination of the plaintiff minority shareholder, the plaintiff failed to establish a sufficient basis for a breach of fiduciary duty claim because “the termination [was not] for the financial gain of [the majority shareholder] or contrary to established public policy . . . [the plaintiff] was terminated in accordance with his employment contract and fairly compensated for his stock.” Id.

2003Although the Court acknowledged, citing Wilkes, supra, that the termination of a minority shareholder’s employment may present a situation where the majorily has committed a breach of fiduciary duiy, the Court went on to state that “not every discharge of an at-will employee of a close corporation who happens to own stock in the corporation gives rise to a successful breach of fiduciary duty claim.” Id. at 464, 466.

12003–2003
Donahue v. Rodd Electrotype Co. of New England, Inc. green
mass · 1975
1 sentence

1996He failed to establish a sufficient basis for a breach of fiduciary duty claim under the principles of Donahue v. Rodd Electrotype Co., supra. The plaintiff’s cross appeal.

11996–1996

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 260, § 2A (4)

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

TX 277 (1999–2026) NY 167 (1998–2026) CA 89 (1990–2026) DE 75 (1996–2026) IL 67 (1991–2025) OH 45 (1999–2026) NC 40 (1989–2026) GA 25 (1989–2026) PA 25 (1986–2024) WA 22 (2000–2026) CO 21 (1987–2026) FL 16 (1984–2026) UT 15 (2010–2025) MA 13 (1996–2026) SC 13 (2004–2025) MO 13 (1990–2024) MD 12 (1991–2022) MI 11 (2002–2025) AL 11 (1987–2018) WI 11 (2005–2025) ME 11 (2002–2023) LA 10 (1988–2022) KY 10 (2013–2025) NJ 9 (2002–2026) IN 9 (2001–2025) VA 9 (1996–2026) AZ 8 (1999–2023) IA 8 (2000–2023) CT 8 (1998–2025) DC 8 (1992–2025) OR 8 (1979–2015) MN 7 (1999–2024) MS 6 (2001–2009) ID 6 (1992–2026) NM 5 (1997–2018) WV 5 (2018–2023) KS 5 (1992–2026) ND 4 (2004–2010) RI 4 (2003–2019) OK 3 (2009–2017) SD 2 (2009–2014) AK 2 (2010–2019) NV 2 (2010–2024) HI 2 (2025–2025)

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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