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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Section 4

Citation
Section 4
Parent Document
Solomon v. Birger, 477 N.E.2d 137 (1985)
Jurisdiction
Massachusetts (state)
Effective Date
1985-04-22

Full Text

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[7] To be distinguished are cases, such as those relied upon by the plaintiffs, which recognize a cause of action in contract by a buyer against a builder-seller based on an implied warranty of habitability or an analogous theory. See, e.g., Duncan v. Schuster-Graham Homes, Inc., 194 Colo. 441, 442-444 (1978); Crowder v. Vandendeale, 564 S.W.2d 879 (Mo. 1978) (en banc). Warranties of habitability are not normally implied in the transfer of a home from one purchaser to a subsequent one. See Crowder v. Vandendeale, supra at 881-882; Casavant v. Campopiano, 114 R.I. 24, 26-27 (1974). Compare Roberts, The Case of the Unwary Home Buyer: The Housing Merchant Did It, 52 Cornell L.Q. 835, 841-843 (1967); 12 Williston, Contracts §§ 1506A, 1523 (3d ed. 1970). Others of the plaintiffs' cases involve equitable relief, e.g., Wolford v. Freeman, 150 Neb. 537 (1948) (rescission), which if sought — as it was not here — would be subject to equitable time limitations. See 12 Williston, supra § 1526. [8] G.L.c. 260, § 2A, as amended by St. 1973, c. 777, § 1.