Massachusetts Appeals Court Vacates Civil Conspiracy Verdict on Chapter 93A Claim
Massachusetts Appeals Court vacated a civil conspiracy verdict, ruling disputed facts preclude liability under Chapter 93A.
Why it matters: It clarifies that factual disputes must be resolved at trial before liability under Massachusetts Chapter 93A can be found. Litigators get clearer standards for unfair or deceptive act claims in civil conspiracy suits.
- On July 21, 2026, the Massachusetts Appeals Court vacated a civil conspiracy verdict involving a Chapter 93A claim.
- The trial court had granted summary judgment for plaintiffs, accepting a commercial extortion theory under Chapter 93A.
- The Appeals Court ruled genuine disputes of material fact required trial resolution, vacating the judgment.
- The court emphasized that mere disagreements over contracts do not constitute unfair or deceptive acts under Massachusetts law.
On July 21, 2026, the Massachusetts Appeals Court vacated a civil conspiracy verdict after defendants appealed a ruling involving Massachusetts Chapter 93A, the state’s consumer protection statute.
The dispute centered on allegations that the defendants committed commercial extortion by threatening to impede a business transaction unless the plaintiffs reduced certain fees. At trial, the court granted summary judgment in favor of the plaintiffs, accepting the commercial extortion claim as an unfair or deceptive act under Chapter 93A.
On appeal, the Massachusetts Appeals Court found that genuine disputes of material fact about the defendants’ motivations and the circumstances existed, which precluded summary judgment. The court vacated the lower court’s judgment and remanded the case for further proceedings.
This ruling clarifies that disagreements or disputes concerning contractual terms or amounts owed do not automatically amount to unfair or deceptive conduct under Chapter 93A. Instead, courts must consider whether the evidence truly supports liability, especially in civil conspiracy claims involving consumer protection.
Angela C. Bunnell, a shareholder at Greenberg Traurig LLP, commented on the decision: “This ruling reinforces that a business dispute alone—such as differing views on contract obligations—does not transform into an unfair or deceptive act under Chapter 93A without more.”
The case provides important guidance for litigators and in-house counsel managing complex consumer protection claims and civil conspiracy allegations in Massachusetts.
By the numbers:
- July 21, 2026 — Date of Massachusetts Appeals Court ruling
- One — Number of civil conspiracy verdicts vacated by Appeals Court
- Chapter 93A — Massachusetts consumer protection statute at issue