Court Discusses Claim Preclusion Under Massachusetts Law

Smoking is a deadly habit, and thousands of people die from smoking-related illnesses each year. People in modern society generally understand cigarettes to be dangerous, but in prior times the risks associated with smoking were less clear. As such, in the late 1990s, the Attorney General filed a complaint against cigarette manufacturers and obtained substantial damages via a settlement agreement. The agreement did not preclude other parties from pursuing claims against cigarette manufacturers, though, as illustrated in a recent Massachusetts ruling issued in a wrongful death case. If you suffered harm due to a dangerous product, you might be owed compensation, and it is in your best interest to meet with a trusted Massachusetts personal injury lawyer to evaluate your potential claims.

The History of Proceedings

Allegedly, the plaintiff, the wife of a deceased smoker, brought wrongful death claims against the defendant, the cigarette manufacturer. The complaint alleged, among other things, that the defendant caused the plaintiff’s husband’s death by selling unreasonably dangerous and defective cigarettes. The case proceeded to trial, and the jury found in favor of the plaintiff. The court entered a judgment in the plaintiff’s favor, and the defendant appealed.

Claim Preclusion Under Massachusetts Law

On appeal, the defendant argued that the plaintiff’s claims were precluded by a previous settlement agreement between the State Attorney General and the defendant. The appellate ultimately disagreed and affirmed the trial court ruling.

The appellate court explained that, pursuant to Massachusetts law, the doctrine of claim preclusion renders a final, valid judgment conclusive on the parties and their privies. As such, it prevents them from relitigating matters that were or could have been decided in the previous action. The doctrine arises out of the idea that the party to be precluded had the motive and opportunity to fully litigate the issue in the initial lawsuit.

A party arguing claim preclusion applies must establish three elements: the privity of parties in the prior and current action, the identity of the cause of action, and a previous final judgment on the merits. In the subject case, the appellate court found that the plaintiff was not in privity with the Attorney General in the previous matter. Specifically, the court explained that the plaintiff sought punitive damages under the wrongful death statute in the current case, and the interest in such damages was not represented in the prior proceeding. As such, her claims against the defendant were not precluded, and the appellate court denied the defendant’s appeal.

Contact a Lawyer in Massachusetts About Your Case

Companies have an obligation to warn consumers of the risks associated with the use of their products, and if they do not, they should be held accountable. If you were hurt by an unsafe product, you should contact a lawyer to discuss whether you may be owed damages. The dedicated wrongful death attorneys of The Law Offices of John C. Manoog, III, can assess the circumstances surrounding your harm and advise you regarding what compensation you may be able to recover. You can contact us through our form online or at 888-262-6664 to set up a meeting.


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