Wicked Lite Supply Inc Another V Woodforest Lighting Inc Others

Key Facts

Transaction Type

Issues

• The court assessed whether the judge correctly awarded treble damages under c. 93A based on the defendants' knowing and willful conduct in selling defective products and providing unsuitable replacements.
• The court determined whether the defendants' conduct, including selling defective products and misrepresenting solutions, constituted an unfair or deceptive act under G. L. c. 93A, § 2.
• The court evaluated whether a transmittal e-mail from a Woodforest employee and an attached test report were properly admitted into evidence, addressing claims of hearsay and lack of authentication.

Holdings

• The jury found in favor of Wicked-Lite Supply, Inc. on its breach of warranty claim against Woodforest Lighting, Inc., and on its claims of misrepresentation and violation of G. L. c. 93A against both Woodforest and MLS. The court affirmed the judge's decision to triple damages under c. 93A based on the defendants' knowing and willful conduct.
• The court upheld the judge's admission of a transmittal e-mail and test report, stating the evidence supported the jury's findings of unfair and deceptive practices. Any error in admitting the report was not prejudicial due to sufficient corroborating evidence.
• The court rejected the defendants' arguments that their conduct amounted to mere breach of contract, emphasizing that their willful misrepresentation and unsuitable replacement fixtures constituted unfair and deceptive practices under c. 93A.
• The judge's award of appellate attorney's fees and costs to Wicked-Lite under c. 93A, § 11 was confirmed, with a deadline for submitting a fee petition within 14 days of the decision.

Remedies

• The court awarded trebled damages under G. L. c. 93A, § 11 for the defendants' knowing and willful violations of the statute.
• Attorney's fees and costs were awarded to the plaintiffs as part of their victory on the c. 93A claims, which the judge approved based on the jury's advisory verdicts.
• Plaintiffs were entitled to appellate attorney's fees and costs under G. L. c. 93A, § 11 and were instructed to submit a petition with supporting materials within 14 days.

Legal Principles

Precedent Name

• H1 Lincoln, Inc. v. South Washington St., LLC
• Baudanza v. Comcast of Mass. I, Inc.
• Anthony's Pier Four, Inc. v. HBC Assocs.
• Pardo v. General Hosp. Corp.
• VMark Software, Inc. v. EMC Corp.
• Kace v. Liang
• Hug v. Gargano & Assocs., P.C.
• Hopkins v. Medeiros
• Chace v. Curran
• Laramie v. Philip Morris USA Inc.
• Quarterman v. Springfield
• Twin Fires Inv., LLC v. Morgan Stanley Dean Witter & Co.
• Commonwealth v. Purdy
• Brewster Wallcovering Co. v. Blue Mountain Wallcoverings, Inc.
• Connor v. Marriott Int'l, Inc.

Key Disputed Contract Clauses

• The court analyzed whether Woodforest Lighting, Inc. breached its express warranty by supplying defective T5N LED lamps that failed and flickered after installation, leading to the jury's finding in favor of the plaintiff on this claim.
• The jury rejected the plaintiff's claim of breach of the implied warranty of merchantability, indicating the court did not find sufficient evidence to support this statutory warranty violation.

Cited Statute

• Massachusetts General Laws Chapter 93A
• Massachusetts General Laws on Evidence

Judge Name

• Vuono
• Hershfang
• Tan

Passage Text

• The judge's findings that the defendants had violated c. 93A were based on conduct distinct from any breach of contract or related warranty issue. Woodforest knew or should have known that the lights were defective, and, despite this knowledge, continued to sell the products to Wicked. Its 'purported remedy,' approved by MLS, was to 'knowingly provide alternative fixtures that would not fit and were not suitable for the use to which they were to be put.'
• Following a trial in Superior Court, the jury found in favor of Wicked on its breach of warranty claim against Woodforest, and on its claims of misrepresentation and violation of c. 93A against both Woodforest and MLS. The jury found against Wicked on its claim for breach of the implied warranty of merchantability. In a posttrial memorandum and order, the judge credited the jury's findings that both Woodforest and MLS knowingly and willfully engaged in unfair and deceptive acts or practices and entered judgment tripling Wicked's damages under c. 93A.
• The court concluded that the evidence supported the judge's findings that the defendants' behavior was intentional and willful, stating, 'Where, as here, the evidence supports the judge's conclusion that the defendants' behavior was intentional and willful, we do not disturb his award of treble damages.'

Damages / Relief Type

• Attorney's fees and costs awarded to the plaintiff under c. 93A.
• Trebled damages under G.L. c. 93A, §11 awarded for knowing and willful violations.