Massachusetts Court Rejects Chapter 93A Claim in Nonpayment Dispute

Ruling highlights high bar for converting contract breach into unfair or deceptive conduct claim

Apr. 17, 2026 at 6:09am

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A photorealistic studio still life featuring a stack of unpaid invoices and a pen resting on a clean, monochromatic background, symbolizing the abstract corporate strategy and finance issues at the heart of this legal dispute.A high-stakes legal battle over unpaid consulting fees exposes the complexities of transforming a standard contract dispute into a consumer protection claim.Boston Today

A Massachusetts federal court has rejected a plaintiff's attempt to transform a straightforward nonpayment dispute into a viable claim under Chapter 93A, the state's consumer protection law. The court held that the plaintiff's allegations were insufficient, as Chapter 93A liability requires more than mere nonpayment or a knowing breach of contract - the plaintiff must show the defendant engaged in conduct with a 'coercive quality' or used the breach as leverage to obtain an unwarranted benefit.

Why it matters

This ruling reinforces that plaintiffs must plead specific, non-conclusory facts demonstrating unfair or deceptive conduct to sustain a Chapter 93A claim, and that courts will not allow plaintiffs to 'bootstrap' such claims onto ordinary contract disputes. It provides guidance to businesses on the high bar for converting a payment dispute into an actionable Chapter 93A violation.

The details

In CRA International, Inc. v. duPont Registry Group, the U.S. District Court for the District of Massachusetts addressed whether a plaintiff can transform a nonpayment dispute into a viable Chapter 93A claim. CRA alleged that duPont Registry Group (DRG) violated Chapter 93A by willfully refusing to pay nearly $1 million in invoices. However, the court held that CRA's allegations were insufficient, as Chapter 93A liability requires more than mere nonpayment or even a knowing breach of contract. Instead, the plaintiff must show the defendant engaged in conduct with a 'coercive quality' or used the breach as leverage to obtain an unwarranted benefit. The court found CRA's complaint relied on conclusory assertions but lacked factual details suggesting extortionate conduct, bad-faith leverage, or other aggravating circumstances beyond a payment dispute.

  • The court issued its ruling on April 6, 2026.

The players

CRA International, Inc.

A plaintiff that alleged duPont Registry Group violated Chapter 93A by willfully refusing to pay nearly $1 million in invoices for consulting services.

duPont Registry Group (DRG)

The defendant that was accused of violating Chapter 93A by willfully refusing to pay the invoices.

United States District Court for the District of Massachusetts

The federal court that addressed whether CRA could transform the nonpayment dispute into a viable Chapter 93A claim.

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What’s next

The court's ruling reinforces that plaintiffs must plead specific, non-conclusory facts demonstrating unfair or deceptive conduct at the outset of the case, and that later advocacy to cure deficiencies may be insufficient. Where a complaint alleges nothing more than nonpayment under a contract, a targeted Rule 12(b)(6) motion may help eliminate Chapter 93A exposure at the pleading stage.

The takeaway

This case highlights the high bar for converting a straightforward breach of contract dispute into an actionable claim under Massachusetts' consumer protection law, Chapter 93A. It underscores that merely alleging willful nonpayment is typically not enough, and plaintiffs must plead specific facts demonstrating the defendant engaged in conduct beyond a typical contract breach in order to sustain a 93A claim.