# Gram v. Liberty Mutual Insurance

> Massachusetts Supreme Judicial Court · March 6, 1984 · 391 Mass. 333

URL: https://www.frixlaw.com/law-library/cases/6449731

## Case

- **Full name:** Robert E. Gram v. Liberty Mutual Insurance Company
- **Court:** Massachusetts Supreme Judicial Court
- **Decided:** March 6, 1984
- **Citations:** 391 Mass. 333; 461 N.E.2d 796; 44 A.L.R. 4th 1119; 118 L.R.R.M. (BNA) 2401; 1984 Mass. LEXIS 1389
- **Precedential status:** Published
- **Opinion:** Dissent by Nolan
- **Judges:** Liacos, Nolan, Wilkins
- **Cited by:** 65 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/6449731

## How later opinions describe it (automated extraction)

- emphasizing its holding in Gram I, 384 Mass. at 672, 429 N.E.2d 21, that “the obligation of good faith and fair dealing imposed on an employer requires that the employer be liable for the loss of compensation that is so clearly related to an employee[ at willj’s past service, …
- explaining that although future renewal commissions tied to insurance salesman’s past services were recoverable, salesman was not entitled to “speculative” commissions on anticipated policy changes that might affect policy costs

## Opinion text

Nolan, J.
(dissenting). I am constrained (unhappily) to file this separate dissent because the trial judge followed the teaching of Gram I and that is the only issue in this case. However, I cannot resist adding that my worst fears of a jury’s “extravagant speculation” (Gram I, supra at 674-675) have materialized in the new judgment, which exceeds the first judgment by $225,000. And now for round No. 3. Iterum, pro dolor.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/6449731. Public record. Not legal advice.