Primarque Products Co. v. Williams West & Witt's Products Co., No. 19-1463 (1st Cir. 2021)Annotate this Case
In this appeal and cross-appeal stemming from litigation that followed the termination of an almost forty-year business relationship between a company that manufactured and supplied soup base products (Manufacturer) and a company that distributed them (Distributor), the First Circuit reversed in part and vacated in part Distributor's appeal and affirmed in Manufacturer's cross appeal, holding that the district court erred in part.
Following a trial, the jury awarded Distributor $255,000 in damages for its state law breach of contract and tortious interference with business relationships claims against Manufacturer. The district court granted summary judgment to Manufacturer on Distributor's claim against it under Mass. Gen. Laws ch. 93A and to Manufacturer on its counterclaim for breach of contract, for which the court awarded Manufacturer $97,843 in damages. The First Circuit held that the district court (1) erred in granting summary judgment on the Chapter 93A claim; (2) erred in striking as duplicative the jury's damages award on Distributor's breach of contract claim; (3) erred in denying Distributor prejudgment interest on the damages award it received on the tortious interference with business relations claim; and (4) erred in denying Distributor's offset request.