Rockland Trust Co. v. Langone
477 Mass. 230
| Mass. | 2017Background
- Rockland sued Robert Langone in District Court as guarantor on promissory notes after Aunyx defaulted; initial judgment for Rockland was vacated and the case reopened.
- Langone asserted a compulsory counterclaim alleging fraud, seeking $110,000 in damages related to the same loan transactions.
- Rockland moved to dismiss the counterclaim under Mass. R. Civ. P. 12(b)(10) and G. L. c. 218, §§ 19 and 19A, arguing the District Court may not entertain counterclaims likely to recover more than $25,000.
- The District Court judge denied the motion, concluding she had discretion to retain the case; a single justice denied Rockland’s petition for relief under G. L. c. 211, § 3.
- The Supreme Judicial Court, exercising superintendence, considered whether the District Court must dismiss compulsory counterclaims exceeding the $25,000 procedural limit.
Issues
| Issue | Rockland's Argument | Langone's Argument | Held |
|---|---|---|---|
| Whether §§ 19/19A and Mass. R. Civ. P. 12(b)(10) require dismissal of a compulsory counterclaim that is reasonably likely to recover more than $25,000 | §19’s reference to “plaintiff” includes a plaintiff-in-counterclaim, so the District Court must dismiss counterclaims over $25,000 when timely asserted | “Plaintiff” means the original plaintiff only; §19 is a procedural limit on original plaintiffs and does not bar compulsory counterclaims exceeding $25,000 | The District Court may proceed with a compulsory counterclaim exceeding $25,000; §19 does not require dismissal of such counterclaims |
Key Cases Cited
- Sperounes v. Farese, 449 Mass. 800 (Mass. 2007) (District Court procedural amount is nonjurisdictional; timely objection requires dismissal but judge may retain if not timely raised)
- Ravnikar v. Bogojavlensky, 438 Mass. 627 (Mass. 2003) (one-trial system allows District Court to resolve entire case when at least one claim is within District Court jurisdiction)
- Herman v. Home Depot, 436 Mass. 210 (Mass. 2002) (District Court may exercise equitable powers and jurisdiction akin to Superior Court under one-trial reforms)
- Zizza v. Zizza, 456 Mass. 401 (Mass. 2010) (one-trial system aims to increase trial efficiency and avoid bifurcated proceedings)
- Meikle v. Nurse, 474 Mass. 207 (Mass. 2016) (statutory interpretation reviewed de novo; plain statutory language controls)