Rodriguez v. Massachusetts Bay Transportation Authority
AC 16-P-942
| Mass. App. Ct. | Jul 31, 2017Background:
- Rodriguez purchased a Zone 1 monthly MBTA commuter-rail pass for Jan–Mar 2015 and sued on behalf of similarly situated purchasers after severe winter storms disrupted service.
- Record-setting snowstorms in Jan–Mar 2015 led to widespread cancellations, a reduced "winter recovery" schedule, and very limited weekday service in March.
- Rodriguez alleged an implied contract: in exchange for pass monies, the MBTA agreed to provide "timely, reliable" commuter-rail service and that the MBTA breached this contract by failing to provide timely service, adequate schedule updates, and by adopting the sparse recovery schedule.
- The Superior Court allowed MBTA’s motion to dismiss under Mass. R. Civ. P. 12(b)(6), concluding the complaint failed to allege agreement on material contract terms or present intent to be bound.
- Rodriguez appealed only the MBTA contract claim; she did not pursue her claims against the operator Keolis or her unjust-enrichment argument on appeal.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether purchase of a monthly pass created an enforceable contract obligating MBTA to provide "timely, reliable" service | Rodriguez: buying a pass formed a contract (like Sears) whose terms include performance according to normal/published schedules | MBTA: no express contract terms were agreed; schedule publications are not a binding promise to performance in extraordinary conditions | Court: Dismissed — complaint fails to allege material, definite contract terms or intent to be bound |
| Whether MBTA’s schedule changes during severe storms breached any implied contractual term | Rodriguez: reduced/irregular service and inadequate updates made passes unusable | MBTA: service changes were weather-driven emergency measures and not unilateral breaches of a defined contractual promise | Court: Dismissed — alleged term "timely and reliable" is too indefinite; weather emergency distinguishes case from binding-schedule precedents |
| Whether published schedules (or normal service) can be treated as binding contractual terms | Rodriguez: the MBTA’s published schedule (or regular service) should be an implied term of the contract | MBTA: publishing a timetable is not an unconditional promise; no allegation MBTA intended to be bound to the schedule | Court: Dismissed — complaint does not plausibly allege MBTA intended to be bound by schedule terms |
| Whether plaintiff pleaded sufficient facts to survive 12(b)(6) | Rodriguez: alleged mismanagement and specific service failures make breach plausible | MBTA: allegations are conclusory and do not identify material contract terms or customer remedies | Court: Dismissed — pleading insufficient as a matter of law to state a breach claim |
Key Cases Cited
- Schaer v. Brandeis Univ., 432 Mass. 474 (court of review standard for pleadings and record consideration)
- Iannacchino v. Ford Motor Co., 451 Mass. 623 (plausibility standard for pleadings)
- Curtis v. Herb Chambers I-95, Inc., 458 Mass. 674 (standard of review on motion to dismiss)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Twombly pleading standard applied to plausibility)
- Lambert v. Fleet Natl. Bank, 449 Mass. 119 (agreement and intent to be bound required for enforceable contract)
- Situation Mgmt. Sys., Inc. v. Malouf, Inc., 430 Mass. 875 (material terms and present intent required)
- Targus Group Intl., Inc. v. Sherman, 76 Mass. App. Ct. 421 (definiteness and present intent elements)
- Duff v. McKay, 89 Mass. App. Ct. 538 (question of law whether terms are definite)
- Epstein v. Zwetchkenbaum, 356 Mass. 22 (contract terms require certainty and precision)
- McCarthy v. Tobin, 429 Mass. 84 (inference that party intended to be bound by published schedule is not reasonable)