Massachusetts General Laws
Mass. Gen. Laws ch. 93, § 94 (2026)
Contract for purchase and sale of propane gas
✓ current as of July 2026
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Section 94. A contract or agreement between a propane gas dealer and a real property owner for the purchase and sale of propane gas shall not be binding upon or enforceable against a subsequent purchaser of said real property.
Notes of Decisions
Cited in 3
cases (3 in the last 5 years), 2021–2025 · leading case: Hopkinson v. Pennsylvania Higher Educ. Assistance Agency (D. Mass. 2022).
Hopkinson v. Pennsylvania Higher Educ. Assistance Agency (D. Mass. 2022). “In addition, violations of the Fair Debt Collection Practices Act (“FDCPA”) and the Massachusetts unfair debt collection statute, Mass. Gen. Laws ch. 93 § 94, are per se Chapter 93A violations.”
Tommy Royal & Bernadette Costa, Individually & on Behalf of Similarly Situated Individuals v. Andrew Metcalf, Judgment Acquisitions Unlimited Inc., & Michael Zola (Mass. Super. Ct. 2025). “The summary judgment record also establishes that Metcalf’s violations of G.L. c. 93, § 94, and per se violations of G.”
Hopkinson v. Pennsylvania Higher Educ. Assistance Agency (D. Mass. 2021). “McDermott is of no assistance, however, because Plaintiff has not pleaded a claim against Great Lakes under the FDCPA or under Massachusetts’ unfair debt collection statute.”
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