Where a defendant university has moved for judgment on the pleadings in a Wage Act suit, the motion should be allowed based on a statutory amendment that provides immunity to nonprofit institutions of higher education.
“On July 4, 2025, Massachusetts Governor Maura Healey signed a budget bill into law, which included Section 113 of Chapter 9 of the Acts and Resolves of 2025 (Section 113). Section 113 provides immunity to nonprofit institutions of higher education and nonprofit organizations that comprise a health care delivery system from Wage Act lawsuits targeting the employers’ monthly payment of wages to employees. …
“BU argues that judgment on the pleadings is appropriate because Section 113 provides statutory immunity to BU based on a plain reading of the legislation. …
“… The court agrees with the parties that the plain language of Section 113 immunizes BU from liability for [plaintiff Lydia] Curtin-Wilding’s Wage Act claim that BU paid her on a monthly basis. … Curtin-Wilding’s claim, which was filed on February 21, 2025, squarely falls within the applicable statutory period. …
“In evaluating the reasonableness of a retroactive statute, the court weighs three factors: ‘(1) the nature of the public interest which explicitly or may have motivated the Legislature to enact the retroactive statute; (2) the nature of the rights affected retroactively and the reasonableness of any reliance expectations on those rights; and (3) the extent or scope of the statutory effect...
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