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Massachusetts Court Discusses Settlements in Personal Injury Cases with Multiple Defendants

It is not uncommon for a victim who has suffered injuries to name more than one defendant in a civil lawsuit. While naming multiple defendants allows a plaintiff to seek compensation from anyone liable for his or her harm, it may present issues in resolving claims against the defendants individually. This was demonstrated in a recent personal injury case decided by a Massachusetts appellate court, in which the court vacated a defendant’s order for certification of separate and final judgment. If you suffered harm due to the negligence of multiple parties, it is in your best interest to meet with a knowledgeable Massachusetts personal injury attorney to assess the claims that you may be able to pursue.

Factual Background of the Case

The plaintiff was a tenant of the defendant property owner. The stove in the plaintiff’s apartment was defective, but, rather than replace it, the defendant property owner hired the defendant repair company to repair the stove on three different occasions. The defendant repair company ultimately advised the plaintiff that the stove was fixed. When the plaintiff attempted to light the pilot light after it went out, however, he suffered severe burns on his right hand. He subsequently filed a lawsuit against both defendants.

The plaintiff and the defendant repair company reached a settlement and executed a release. The defendant repair company then filed a motion for entry of a final and separate judgment. The defendant property owner opposed the motion on the grounds that it was not warranted and that he had outstanding claims for indemnification. The judge granted the motion regardless, and the defendant property owner appealed.

Rule 54b Certification Under Massachusetts Law  

Under Massachusetts law, for a court to grant a Rule 54b certification, the party seeking certification must show that the lawsuit involves more than one claim or party, a final resolution of one but not all claims or parties, an express direction at the entry of judgment, and an explicit finding that there is not a valid reason for delaying the appeal until the remainder of the claims are resolved. Rule 54b was drafted to avoid the potential injustice of entering judgment on a distinct claim as to less than all the parties until the final resolution of all claims, by making an immediate appeal available.

On reviewing a Rule 54b motion, an appellate court will determine whether the underlying claims are so interrelated that the case should only be reviewed as a single unit. A party’s claims for relief will be separate and distinct when the facts give rise to more than one cause of action. Conversely, if the party asserts only one right, even if there are multiple claims or parties, there is only one claim for relief under Rule 54b. In other words, if the facts underlying the claims that have been resolved are the same as those that are pending against the remaining defendants, there is only a single claim for relief. In the subject case, the court found that the plaintiff’s complaint alleged different legal theories arising out of one set of facts. Thus, they constituted one claim, and the trial court erred in granting the defendant repair company’s motion.

Meet with a Trusted Personal Injury Attorney

If you were injured in an accident that was caused by multiple parties’ lack of care, it is in your best interest to meet with a trusted Massachusetts personal injury attorney regarding your options for seeking compensation from the parties responsible for your harm. The skillful personal injury attorneys at Karsner & Meehan will assertively advocate on your behalf to help you seek the full amount of compensation that you might be able to recover. We can be contacted at 508-822-6600 or through our form online to set up a meeting.