Massachusetts General Laws

Mass. Gen. Laws ch. 223, § 2A (2026)

Consolidation of pending actions arising out of same accident or transaction

✓ current as of July 2026

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Section 2A. Whenever cross actions between the same parties or two or more actions, including for the purposes hereof other court proceedings and actions transferred under section one hundred and two C of chapter two hundred and thirty-one, arising out of or connected with the same accident, event or transaction are pending in more than one division of the same department of the trial court, the administrative justice of such department of the trial court may, upon motion of any party to such action in such court, order the consolidation of such actions for the purpose of trial together in any division of said department of the trial court to be designated in the order. The party making such motion shall give notice thereof to the clerks, clerk magistrates or registers of probate of the divisions in which said actions are pending, to all parties to such actions, and to the administrative justice of the respective department of the trial court. Thereafter, none of said actions shall be placed on any trial list until after the disposition of said motion. This section shall apply only to actions as to which the time limit for removal to the superior court department under section one hundred and four of chapter two hundred and thirty-one has expired.

Notes of Decisions

Cited in 7 cases, 1956–2000 · leading case: Salter v. Scott, 294 N.E.2d 219 (Mass. 1973).

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Salter v. Scott, 294 N.E.2d 219 (Mass. 1973). “223, § 2B) and a consolidation in the District Court (G. L. c. 223, § 2A), in the context of the statute it seems likely that only consolidations at the District Court level are referred to and, because of what we have said, need be referred to.”

Miller v. Norton, 232 N.E.2d 351 (Mass. 1967). “See G. L. c. 223, §§ 2A and 2B, as amended. 2 The record does not show that the trial judge, upon the return of the verdict in the principal action, did anything (e.”

E. Tank of Peabody, Inc. v. Moore, 1986 Mass. App. Div. 58 (Mass. Dist. Ct., App. Div. 1986). “See G.L. c. 223, § 2A, as amended by St. 1985, c.”

Rasten v. Zimbovsky, 2000 Mass. App. Div. 204 (Mass. Dist. Ct., App. Div. 2000). “Pursuant to G.L.c. 223, §2A, Rasten could only have brought this action in the judicial district where she or Zimbovsky lived or had a place of business or in the adjacent judicial district.”

Checker Taxi Co. v. Scopa, 49 Mass. App. Dec. 128 (Mass. Dist. Ct., App. Div. 1972). · cites it 2× “The cases were properly consolidated under the provisions of G.L. c. 223, § 2A. The third paragraph of G.”

Thibault-Royer v. Borrelli, 49 Mass. App. Dec. 134 (Mass. Dist. Ct., App. Div. 1972). · cites it 2× “G.L. c. 223, § 2A. We can read in the statute no additional circumstances under which a case originating in a District Court can be engrafted upon a remanded case for the purpose of transfer to the Superior Court for a second trial upon the merits.”

Garbutt v. Finn, 12 Mass. App. Dec. 159 (Mass. Dist. Ct., App. Div. 1956). “One of the statutes cited by the plaintiffs dealing with consolidation of actions for trial is G. L. c. 223, §2A, which allows the Appellate Divisions of District Courts to consolidate for trial "cross actions between the same parties or two or more actions, including for the…”

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