unfairness rule (Massachusetts) · Go Syfert
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unfairness rule in Massachusetts

9 Massachusetts opinions name it 3 courts 1995–2024 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 (11)

CaseFollowedCited
Bowen v. Eli Lilly & Co.green
mass · 1990 · cited in 4 Massachusetts opinions naming this issue, 1995–2024
2 sentences

2024However, we have also "recognized the unfairness of a rule that holds that the statute of limitations has run even before a plaintiff knew or reasonably should have known that she may have been harmed by the conduct of another." Bowen v. Eli Lilly & Co., 408 Mass. 204, 205 (1990).

2017L. c. 260, §§ 2A (torts), 5A (c. 93A); Stark 8 Fraud and deceit, intentional and negligent misrepresentation, civil conspiracy, unjust enrichment, and tortious interference with contractual relations. 14 v. Advanced Magnetics, Inc., 50 Mass. App. Ct. 226, 232 (2000).9 However, recognizing the unfairness of a rule that allows statutes of limitation to run even before a plaintiff knew or reasonably should have known that it may have been harmed, the Supreme Judicial Court has adopted "a discovery rule for the purpose of determining when a cause of action accrues, and thus when the statute of lim

34
Olsen v. BELL TELEPHONE LABORATORIES, W. ELECTRIC CO.green
mass · 1983 · cited in 3 Massachusetts opinions naming this issue, 2000–2006
2 sentences

2006Labs., Inc., 388 Mass. 171, 175 (1983).

2002Labs., Inc., 388 Mass. 171, 175 (1983).

33
Hendrickson v. Searsgreen
mass · 1974 · cited in 2 Massachusetts opinions naming this issue, 1996–2024
2 sentences

2024See Hendrickson v. Sears, 365 Mass. 83, 89-90 (1974) (collecting cases).

1996The discovery rule has been applied to psychother-apeutic malpractice, Riley v. Presnell, 409 Mass. 239, 243 (1991); medical malpractice, Franklin v. Albert, 381 Mass. 611, 618-19 (1980); real estate fraud, Friedman v. Jablonski, 371 Mass. 482, 485-86 (1976); legal malpractice, Hendrickson v. Sears, 365 Mass. 83, 83-84 (1974); incestuous child abuse, Phinney v. Morgan, 39 Mass.App.Ct. 202, 204 (1995); and misrepresentation, McEneaney v. Chestnut Hill Realty Corp., 38 Mass.App.Ct. 573, 577 (1995).

22
Mohr v. Commonwealthgreen
mass · 1995 · cited in 2 Massachusetts opinions naming this issue, 2002–2006
2 sentences

2006The unfairness of such a rule, however, has been recognized in actions where the wrong is “inherently unknowable.” See Mohr v. Commonwealth, 421 Mass. 147, 155 (1995); Olsen v. Bell Tel.

2002The unfairness of such a rule, however, has been recognized in actions where the wrong is “inherently unknowable.” See Mohr v. Commonwealth, 421 Mass. 147, 155-156 (1995); Olsen v. Bell Tel.

22
Phinney v. Morgangreen
massappct · 1995 · cited in 2 Massachusetts opinions naming this issue, 1996–1996
2 sentences

1996The discovery rule has been applied to psychother-apeutic malpractice, Riley v. Presnell, 409 Mass. 239, 243 (1991); medical malpractice, Franklin v. Albert, 381 Mass. 611, 618-19 (1980); real estate fraud, Friedman v. Jablonski, 371 Mass. 482, 485-86 (1976); legal malpractice, Hendrickson v. Sears, 365 Mass. 83, 83-84 (1974); incestuous child abuse, Phinney v. Morgan, 39 Mass.App.Ct. 202, 204 (1995); and misrepresentation, McEneaney v. Chestnut Hill Realty Corp., 38 Mass.App.Ct. 573, 577 (1995).

1996Phinney v. Morgan, 39 Mass.App.Ct. 202, 204 (1995).

22
Stark v. Advanced Magnetics, Inc.green
massappct · 2000 · cited in 1 Massachusetts opinions naming this issue, 2017–2017
1 sentence

2017L. c. 260, §§ 2A (torts), 5A (c. 93A); Stark 8 Fraud and deceit, intentional and negligent misrepresentation, civil conspiracy, unjust enrichment, and tortious interference with contractual relations. 14 v. Advanced Magnetics, Inc., 50 Mass. App. Ct. 226, 232 (2000).9 However, recognizing the unfairness of a rule that allows statutes of limitation to run even before a plaintiff knew or reasonably should have known that it may have been harmed, the Supreme Judicial Court has adopted "a discovery rule for the purpose of determining when a cause of action accrues, and thus when the statute of lim

11
Atkinson v. Rosenthalgreen
massappct · 1992 · cited in 1 Massachusetts opinions naming this issue, 2006–2006
1 sentence

2006Atkinson v. Rosenthal, 33 Mass.App.Ct. 219, 226 (1992).

11
Riley v. Presnellgreen
mass · 1991 · cited in 1 Massachusetts opinions naming this issue, 1996–1996
1 sentence

1996The discovery rule has been applied to psychother-apeutic malpractice, Riley v. Presnell, 409 Mass. 239, 243 (1991); medical malpractice, Franklin v. Albert, 381 Mass. 611, 618-19 (1980); real estate fraud, Friedman v. Jablonski, 371 Mass. 482, 485-86 (1976); legal malpractice, Hendrickson v. Sears, 365 Mass. 83, 83-84 (1974); incestuous child abuse, Phinney v. Morgan, 39 Mass.App.Ct. 202, 204 (1995); and misrepresentation, McEneaney v. Chestnut Hill Realty Corp., 38 Mass.App.Ct. 573, 577 (1995).

11
McEneaney v. Chestnut Hill Realty Corp.green
massappct · 1995 · cited in 1 Massachusetts opinions naming this issue, 1996–1996
1 sentence

1996The discovery rule has been applied to psychother-apeutic malpractice, Riley v. Presnell, 409 Mass. 239, 243 (1991); medical malpractice, Franklin v. Albert, 381 Mass. 611, 618-19 (1980); real estate fraud, Friedman v. Jablonski, 371 Mass. 482, 485-86 (1976); legal malpractice, Hendrickson v. Sears, 365 Mass. 83, 83-84 (1974); incestuous child abuse, Phinney v. Morgan, 39 Mass.App.Ct. 202, 204 (1995); and misrepresentation, McEneaney v. Chestnut Hill Realty Corp., 38 Mass.App.Ct. 573, 577 (1995).

11
Friedman v. Jablonskigreen
mass · 1976 · cited in 1 Massachusetts opinions naming this issue, 1996–1996
1 sentence

1996The discovery rule has been applied to psychother-apeutic malpractice, Riley v. Presnell, 409 Mass. 239, 243 (1991); medical malpractice, Franklin v. Albert, 381 Mass. 611, 618-19 (1980); real estate fraud, Friedman v. Jablonski, 371 Mass. 482, 485-86 (1976); legal malpractice, Hendrickson v. Sears, 365 Mass. 83, 83-84 (1974); incestuous child abuse, Phinney v. Morgan, 39 Mass.App.Ct. 202, 204 (1995); and misrepresentation, McEneaney v. Chestnut Hill Realty Corp., 38 Mass.App.Ct. 573, 577 (1995).

11
Franklin v. Albertgreen
mass · 1980 · cited in 1 Massachusetts opinions naming this issue, 1996–1996
1 sentence

1996The discovery rule has been applied to psychother-apeutic malpractice, Riley v. Presnell, 409 Mass. 239, 243 (1991); medical malpractice, Franklin v. Albert, 381 Mass. 611, 618-19 (1980); real estate fraud, Friedman v. Jablonski, 371 Mass. 482, 485-86 (1976); legal malpractice, Hendrickson v. Sears, 365 Mass. 83, 83-84 (1974); incestuous child abuse, Phinney v. Morgan, 39 Mass.App.Ct. 202, 204 (1995); and misrepresentation, McEneaney v. Chestnut Hill Realty Corp., 38 Mass.App.Ct. 573, 577 (1995).

11

Distinguished, questioned or overruled (0)

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

Statutes the citing opinions construe

MA § Mass. Gen. Laws ch. 260, § 2A (6) MA § Mass. Gen. Laws ch. 260, § 4C (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

CA 10 (1980–2026) MA 9 (1995–2024) IL 8 (1977–2022) CT 4 (1995–2001) MS 2 (1970–1988) FL 2 (2001–2014) WI 2 (1969–2010) WA 2 (2012–2017) OR 2 (2025–2025) ND 2 (1990–1993) OH 2 (1993–2017)

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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