foreseeability standard (Massachusetts) · Go Syfert
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foreseeability standard in Massachusetts

6 Massachusetts opinions name it 3 courts 1995–2020 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.

Followed or applied (6)

CaseFollowedCited
Schaefer v. Yongjie Fugreen
mad · 2017 · cited in 1 Massachusetts opinions naming this issue, 2020–2020
1 sentence

2020Cf. Schaefer v. Yongjie Fu, 272 F. Supp. 3d 285, 288 (D.

11
Burger King Corp. v. Rudzewiczgreen
scotus · 1985 · cited in 1 Massachusetts opinions naming this issue, 2004–2004
1 sentence

2004Id. at 25 (quoting Burger King Corp. v. Rudwewicz, 471 U.S. 462, 474 (1985)).

11
Bily v. Arthur Young & Co.green
cal · 1992 · cited in 1 Massachusetts opinions naming this issue, 1998–1998
2 sentences

1998We concur with the California Supreme Court’s conclusion in Bily v. Arthur Young & Co., 3 Cal. 4th 370, 394 (1992), that the Restatement test properly balances the indeterminate liability of the foreseeability test and the restrictiveness of the near-privity rule.

1998Section 552 “recognizes commercial realities by avoiding both unlimited and uncertain liability for economic losses in cases of professional mistake and exoneration of the auditor in situations where it clearly intended to undertake the responsibil ity of influencing particular business transactions involving third persons.” Id. at 408 .

11
Palsgraf v. Long Island R.R. Co.green
ny · 1928 · cited in 1 Massachusetts opinions naming this issue, 1998–1998
1 sentence

1998Pursuant to this test, which is derived from traditional tort law concepts as first enunciated in Palsgraf v. Long Island R.R., 248 N.Y. 339, 344 (1928), an accountant may be held liable to any person whom the accountant could reasonably have foreseen would obtain and rely on the accountant’s opinion, including known and unknown investors.

11
Ultramares Corp. v. Touchegreen
ny · 1931 · cited in 1 Massachusetts opinions naming this issue, 1998–1998
1 sentence

1998If we were to apply a foreseeability standard in these circumstances, “a thoughtless slip or blunder, the failure to detect a theft or forgery beneath the cover of deceptive entries, may expose accountants to a liability in an indeterminate amount for an indeterminate time to an indeterminate class.” Ultramares Corp. v. Touche, 255 N.Y. 170, 179 (1931).

11
Simpson v. Specialty Retail Concepts, Inc.green
ncmd · 1995 · cited in 1 Massachusetts opinions naming this issue, 1998–1998
1 sentence

1998See, e.g., Simpson v. Specialty Retail Concepts, Inc., 908 F. Supp. 323 (M.D.N.C. 1995); Blue Bell, Inc. v. Peat, Marwick, Mitchell & Co., 715 S.W.2d 408 (Tex. Ct. App. 1986).

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 (8)

CaseCitedYears
Mullins v. Pine Manor College green
mass · 1983
1 sentence

2020Similarly, students with a history of drinking to the point of alcohol poisoning may pose an enhanced risk to themselves of future physical harm. 25 A.G. posed any risk to the plaintiff.28 While "[p]rior criminal acts are simply one factor" in the foreseeability analysis, see Mullins, 389 Mass. at 56 , we note that nothing in the record indicates that A.G. had a history of sexual assaults, of which Northeastern was aware (or otherwise).

12020–2020
Glick v. Prince Italian Foods of Saugus, Inc. green
massappct · 1987
1 sentence

2018The foreseeability standard, however, "does not require the particular act which caused the injury to have been foreseen, only that the general character and probability of the injury be foreseeable." Glick v. Prince Italian Foods of Saugus, Inc ., 25 Mass. App. Ct. 901 , 902, 514 N.E.2d 100 (1987).

12018–2018
Jesionek v. Massachusetts Port Authority green
mass · 1978
2 sentences

2018In this case, as in Jesionek , 376 Mass. at 106 , 378 N.E.2d 995 , the damage to the plaintiff's property was not, as a matter of law, an unforeseeable consequence of the defendant's failure to secure its equipment. 7 Conclusion .

2018In this case, as in Jesionek , 376 Mass. at 106 , 378 N.E.2d 995 , the damage to the plaintiff's property was not, as a matter of law, an unforeseeable consequence of the defendant's failure to secure its equipment. 7 Conclusion .

12018–2018
Bilt-Rite Contractors, Inc. v. Architectural Studio green
pa · 2005
1 sentence

2006Id. at 285-86 .

12006–2006
Parent v. Stone & Webster Engineering Corp. green
mass · 1990
1 sentence

1998The plaintiff relies on Parent v. Stone & Webster Eng’g Corp., 408 Mass. 108 (1990), and Rae v. Air-Speed, Inc., 386 Mass. 187 (1982), to argue that we have applied the foreseeability doctrine in cases involving the duty of care owed to third parties by various professionals.

11998–1998
Blue Bell, Inc. v. Peat, Marwick, Mitchell & Co. green
texapp · 1986
1 sentence

1998See, e.g., Simpson v. Specialty Retail Concepts, Inc., 908 F. Supp. 323 (M.D.N.C. 1995); Blue Bell, Inc. v. Peat, Marwick, Mitchell & Co., 715 S.W.2d 408 (Tex. Ct. App. 1986).

11998–1998
Rae v. Air-Speed, Inc. green
mass · 1982
1 sentence

1998The plaintiff relies on Parent v. Stone & Webster Eng’g Corp., 408 Mass. 108 (1990), and Rae v. Air-Speed, Inc., 386 Mass. 187 (1982), to argue that we have applied the foreseeability doctrine in cases involving the duty of care owed to third parties by various professionals.

11998–1998
In Re Robert Burns Jensen Rosemary Tooker Jensen, Debtors. California Department of Health Services v. Robert Burns Jensen Rosemary Tooker Jensen green
ca9 · 1993
1 sentence

1995The “fair contemplation” test provides that “all future response and natural resource damages cost based on prepetition conduct that can be fairly contemplated by the parties at the time of [d]ebtors’ bankruptcy are claims under the [Bankruptcy] Code.” In re Jensen, supra at 930 , quoting In re Nat’l Gypsum Co., supra at 409.

11995–1995

Where else courts name it

CA 79 (1960–2025) TX 79 (1976–2026) IL 43 (1969–2015) OH 42 (1991–2025) TN 38 (1992–2025) FL 35 (1960–2026) IN 31 (1984–2025) OR 29 (1952–2024) MD 27 (1958–2025) PA 23 (1985–2025) KS 22 (1979–2026) MI 21 (1959–2025) GA 21 (1964–2024) AZ 18 (1979–2026) WA 17 (1998–2025) NY 16 (1982–2024) CT 16 (1983–2019) UT 16 (1987–2024) DC 13 (1986–2023) DE 12 (1987–2025) MS 12 (1971–2021) IA 11 (1982–2026) NJ 11 (1985–2025) ME 10 (1982–2016) RI 10 (1992–2019) AL 10 (1975–2014) NM 10 (1962–2020) LA 10 (1956–2016) KY 9 (2007–2024) NC 9 (1954–2020) CO 8 (1986–2026) SD 7 (1992–2021) NH 7 (1985–2023) MA 6 (1995–2020) SC 6 (1986–2017) OK 6 (2010–2022) MO 6 (1992–2025) MN 5 (2000–2019) AK 5 (1974–2000) WI 5 (1985–2026) MT 5 (1993–2025) VT 5 (1998–2023) NV 4 (2000–2023) WY 4 (2018–2024) WV 2 (2001–2001) HI 2 (1997–2008) VA 2 (1994–2012)

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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