From Casetext: Smarter Legal Research

Zampell v. Consolidated Freightways Corp.

Appeals Court of Massachusetts
Mar 1, 1983
15 Mass. App. Ct. 954 (Mass. App. Ct. 1983)

Opinion

March 1, 1983.

William H. Shaughnessy for the plaintiff.

Charles W. Ferris, Jr., for the defendant.


Although three years had run since William Zampell, the husband of the plaintiff, suffered an injury which she attributes to the negligence of William's employer, the plaintiff asks that the bar of the statute of limitations (G.L.c. 260, § 2A) be lifted for the reason that her action for emotional distress and loss of consortium was inherently unknowable until the court articulated such a cause of action in Ferriter v. Daniel O'Connell's Sons, 381 Mass. 507 (1980). The same argument was advanced and rejected in Armstrong v. Carlyle Constr. Co., 532 F. Supp. 939, 940-941 (D. Mass. 1982), which we follow. See also Diaz v. Eli Lilly Co., 364 Mass. 153, 167 (1973). Cf. Ferriter v. Daniel O'Connell's Sons, 381 Mass. at 516 n. 12.

In Diaz and Ferriter the court was at some pains to declare that actions under the principles there announced would not be allowed as to claims concluded by the running of the statute of limitations prior to the dates upon which the opinions came down. It surely follows that a claim such as the one at bar, which had not yet been cut off by the statute of limitations on September 9, 1980, when Ferriter came down, and could have been brought before the three-year limitations period expired on February 21, 1981, would not be entitled to a greater right. Contrast Gill v. Northshore Radiological Associates, 10 Mass. App. Ct. 885, 886 (1980).

In instances in which the statute of limitations has been tolled because a wrong was inherently unknowable, it has been the harm which has lain concealed from the plaintiff, either by the nature of the harm, e.g., a latent construction defect, or by active concealment of the harm by the defendant. Facts were unknown, not legal theories. See, e.g., Friedman v. Jablonski, 371 Mass. 482, 484-486 (1976); White v. Peabody Constr. Co., 386 Mass. 121, 123 (1982); Olsen v. Bell Tel. Labs., Inc., 388 Mass. 171, 174-175 (1983); Mansfield v. GAF Corp., 5 Mass. App. Ct. 551, 553-555 (1977). See also, Salinsky v. Perma-Home Corp., ante 193, 197-198 (1983). None of those cases deals with a failure of a plaintiff to know of the legal basis of a claim.

Judgment affirmed.


Summaries of

Zampell v. Consolidated Freightways Corp.

Appeals Court of Massachusetts
Mar 1, 1983
15 Mass. App. Ct. 954 (Mass. App. Ct. 1983)
Case details for

Zampell v. Consolidated Freightways Corp.

Case Details

Full title:LUCY ZAMPELL vs. CONSOLIDATED FREIGHTWAYS CORP

Court:Appeals Court of Massachusetts

Date published: Mar 1, 1983

Citations

15 Mass. App. Ct. 954 (Mass. App. Ct. 1983)
446 N.E.2d 88

Citing Cases

Spencer Furniture, Inc. v. Town of Spencer

Gore v. Daniel O'Connell Sons, Inc., 17 Mass.App.Ct. 645, 647 (1984). Cases presenting such inherently…

Pugliese v. Rodriguez

Contrary to Pugliese's argument, the discovery rule has no application to his claims against MART. Cases…