Lynch v. Crawford
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The Supreme Judicial Court held that Congress intended the Federal Volunteer Protection Act (VPA), 42 U.S.C. 14503(a), to provide qualified immunity from suit for officers in nonprofit organizations who receive no compensation, that the state charitable immunity statute, Mass. Gen. Laws ch. 231, 85W, may only expand the scope of that immunity and that Defendant, as a volunteer for a nonprofit organization, was entitled to interlocutory review of the denial of his motion for summary judgment.
After a company was dissolved, Plaintiffs, former employees of Company, brought suit against Defendant, alleging that, as the company's president, he was among the employers who had violated the Wage Act, Mass. Gen. Laws ch. 149, 148, by failing to pay them the wages they were due. Defendant moved for summary judgment, arguing that even if he were the company's president, he served without compensation and was thus immune from suit under the VPA and section 85W. The superior court denied the motion. The Supreme Judicial Court affirmed, holding that there were genuine issues of material fact as to whether Defendant was placed outside of the immunity otherwise provided by section 85W.
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