Joseph Iannacchino & others v. Ford Motor Company & another

Summary

The Supreme Judicial Court held that although the absence of accident-related injury or a manifested defect does not bar a G. L. c. 93A, § 9 claim premised on overpayment for vehicles that fail federal safety standards, the plaintiffs' complaint failed to allege noncompliance with FMVSS 206 because the GM test Ford used was NHTSA-approved, and bare allegations of 'defect' untethered to a legally required standard cannot state a claim. Because the implied warranty claim rests on the same economic-injury theory and facts, it fails under the same analysis. The court also adopted the Twombly plausibility standard for Mass. R. Civ. P. 12(b)(6) motions, retiring the Conley 'no set of facts' formulation. Dismissals of Counts II, III, and V were affirmed; the rulings on Counts I and IV were reversed, with those counts to be dismissed without prejudice and leave to amend. Justice Cowin concurred in part and dissented in part, agreeing with everything except the without-prejudice dismissal, contending the fatally deficient pleading should suffer the same fate as any initial pleading entitling the claimant to no relief.