WICKED-LITE SUPPLY, INC., & Another v. WOODFOREST LIGHTING, INC., & Others., 24-P-0088

Wicked-Lite Supply, Inc. purchased about 5,500 LED light fixtures from Woodforest Lighting, of which roughly half failed after installation by Wicked Watts, Inc.; both companies are owned by Kelly Cota.
After extensive product failures, Woodforest provided replacement fixtures, but they were incompatible and could not be installed; Wicked-Lite ultimately purchased replacements elsewhere.
Wicked sued Woodforest and its parent company, MLS Co., Ltd., for breach of warranty, misrepresentation, and violation of G.L. c. 93A (regulatory unfair/deceptive practices); similar claims against Ledvance, an affiliated company, were dismissed.
A Massachusetts Superior Court jury found in Wicked’s favor on breach of warranty (against Woodforest) and on misrepresentation and c. 93A claims (against both Woodforest and MLS), finding the violations were willful; damages were trebled under c. 93A; Wicked was awarded attorney’s fees and costs.
Defendants appealed, challenging (1) the admission of certain evidence (an e-mail and test report), (2) whether their conduct violated c. 93A, and (3) the awarding of multiple damages.
The Appeals Court affirmed the judgment for Wicked on all issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of e-mail & ATS test report	Showed knowledge of defect, offered for state of mind	Contained hearsay; report not authenticated	E-mail admissible; report, even if in error, did not cause material prejudice
Violation of G.L. c. 93A (unfair/deceptive practices)	Willful misrepresentation, selling known defective goods	No more than breach of contract; jury rejected warranty claim	Sufficient for c. 93A; conduct went beyond ordinary breach
Multiple damages under c. 93A (§ 11)	Conduct was knowing/willful, justifying trebled damages	Evidence insufficient for willful/knowing standard	Willful and egregious conduct justified tripling damages
Sufficiency of evidence for c. 93A & reliance on jury	Evidence and jury verdict justified findings	Verdict inconsistent/inadequate subsidiary findings	Affirmed; judge entitled to rely on jury advisories and evidence

Pardo v. General Hosp. Corp., 446 Mass. 1 (admission of state of mind evidence for notice or knowledge)
Anthony's Pier Four, Inc. v. HBC Assocs., 411 Mass. 451 (standard for awarding multiple damages under c. 93A)
Baudanza v. Comcast of Mass. I, Inc., 454 Mass. 622 (deference to trial judge's findings in c. 93A cases)
VMark Software, Inc. v. EMC Corp., 37 Mass. App. Ct. 610 (standard for unfair or deceptive practices under c. 93A)
Brewster Wallcovering Co. v. Blue Mountain Wallcoverings, Inc., 68 Mass. App. Ct. 582 (multiple damages flow from willful c. 93A violation)