Debnam v. FedEx Home Delivery, No. 13-2335 (1st Cir. 2014)
Annotate this CasePlaintiff, who had signed an agreement with FedEx classifying him as an independent contractor, filed two claims under Massachusetts law that apply only to employees. The district court dismissed Plaintiff’s claim that FedEx engaged in unfair or deceptive business practices in violation of Mass. Gen. Laws ch. 93A, concluding that the statute generally does not apply to employer/employee relationships. The district court then dismissed Plaintiff’s wage law claim, concluding that Plaintiff was not an employee under the statute. Plaintiff appealed the district court’s dismissal of his Chapter 93A claim. The First Circuit affirmed, holding that, regardless of whether Plaintiff was an employee, the facts in the complaint still failed to plead a violation of Chapter 93A because the allegations did not plausibly establish that Plaintiff and FedEx were interacting in “trade or commerce” within the meaning of Chapter 93A.
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