Massachusetts
How Cottman v. General Motors applies in Massachusetts: state-specific rules, key cases, and bar exam notes for Contracts.
Massachusetts courts recognize that the formation of a contract requires mutual assent, and that a breach of contract can arise from a party's failure to adhere to the agreed-upon terms. In assessing damages, they consider not just direct losses but also consequential damages, depending on foreseeability.
In Massachusetts, to establish a breach of contract, a plaintiff must demonstrate that a valid contract existed, the defendant breached a term of that contract, and the plaintiff suffered damages as a direct result of the breach.
The court affirmed that a party's breach resulting from non-performance of contractual obligations can lead to the recovery of consequential damages if such damages were within the contemplation of both parties at the time of contract formation.
This case underscored the principle that damages should be awarded in a manner that puts the non-breaching party in the position they would have been had the contract been performed.
The court emphasized the necessity for foreseeability in the calculation of damages, stating that recovery is limited to those losses which were reasonably foreseeable at the time the contract was made.
Massachusetts law is consistent with federal standards, particularly regarding mutual assent and damages arising from breaches. However, Massachusetts courts may place a greater emphasis on the foreseeability of damages as a more nuanced aspect of calculating recoverable losses.
The principles from Cottman v. General Motors and Massachusetts' contract law are frequently tested on the Massachusetts bar exam, particularly with respect to breach and the calculation of damages.