Mahan v. Arbella Mutual Insurance

Summary

The Massachusetts Supreme Judicial Court affirmed dismissal of Christine Mahan’s motion to confirm an underinsured motorist arbitration award after Arbella paid the full award. The court held that, because Mahan had been fully paid, she was not entitled to have the award reduced to a judgment for purposes of seeking multiple damages under G. L. c. 93A, while preserving her ability to pursue claims under G. L. c. 93A and G. L. c. 176D.

Holdings

1. Once the arbitration award had been fully paid, Mahan was not entitled to have the award reduced to a judgment that could then be subject to doubling or trebling under G. L. c. 93A.
2. Dismissal of the arbitration-confirmation proceeding did not preclude Mahan from pursuing her claims under G. L. c. 93A and G. L. c. 176D.

Questions Presented

1. Whether the Superior Court was required to confirm the arbitration award under G. L. c. 251, § 11, after Arbella had fully paid the award.
2. Whether a fully paid arbitration award may be reduced to a judgment for purposes of pursuing doubled or trebled damages under G. L. c. 93A.
3. Whether dismissal of the confirmation proceeding precluded Mahan from pursuing separate claims under G. L. c. 93A and G. L. c. 176D.

Disposition

affirmed