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SJC: District Court Has Jurisdiction Over More-Than-$25,000 Counterclaim

Everyone knows that the District Court has jurisdiction over cases “only if there is no reasonable likelihood that recovery by the plaintiff will exceed $25,000.” G. L. c. 218, § 19.  If the amount in controversy will be more than $25,000, the Superior Court has jurisdiction.  But what happens if a defendant brings a counterclaim in which it seeks to recover more than the $25,000 procedural limit?  Must the counterclaim be dismissed and brought in Superior Court?

Presented with this question in Rockland Trust Co. v. Langone, SJC-12129 (June 1, 2017), the Supreme Judicial Court concluded that dismissal is not necessary; the District Court has jurisdiction over such a case.

Relying on the language of c. 218, §§ 17 and 19A, the SJC concluded that the term “plaintiff” applies only to the original plaintiff, not a plaintiff-in-counterclaim.  Moreover, the one-trial system was implemented to “increase the efficacy of trials in the District and Superior Courts over the inefficient remand-removal system that had previously been in effect.” Rockland Trust Co., citing Zizza v. Zizza, 456 Mass. 401, 407 (2010).  A determination that the District Court has jurisdiction over cases where the amount in controversy raised in a counterclaim exceeds $25,000, so long as the original claim did not exceed $25,000, is consistent with the purpose and intent of the one-trial system.  Therefore, the SJC concluded that “given the plain language of §§ 19 and 19A and the purpose of the one-trial system, the District Court may proceed with a case properly before it, where a counterclaim exceeds the $25,000 procedural limit.”