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Silva v. Rent-A-Center, Inc.
Massachusetts Supreme Judicial Court
912 N.E.2d 945, 454 Mass. 667 (2009)
Rent-A-Center, Inc. (defendant) offered short-term leases for a variety of consumer goods, offering its customers the option to purchase the leased goods after a specified period of time. In 2006 Rent-A-Center leased a used laptop to Jaaziel Costa (plaintiff) for weekly payments of approximately $40. Under the rental agreement, Costa could renew the lease at the end of each weekly rental term by paying another $40 rental fee. Costa was not obligated to renew the lease or make any additional payments after each rental period expired. The agreement also provided that Costa could purchase the laptop from Rent-A-Center after renting the laptop for a certain number of weeks. During the rental period, Rent-A-Center retained title in the laptop. Costa and other Rent-A-Center customers (plaintiffs) filed a class-action lawsuit against Rent-A-Center in federal district court, alleging that the rent-to-own agreements offered by Rent-A-Center were not leases, but installment contracts that were governed by the Massachusetts Retail Installment Sales Act (RISA). Rent-A-Center argued that the agreements were leases that were governed by the Massachusetts Consumer Lease Act (CLA). If the agreements were installment contracts under RISA, they would be subject to certain consumer-protection laws. The district court certified the question of whether the rent-to-own agreements were installment contracts to the Massachusetts Supreme Judicial Court.
Rule of Law
Holding and Reasoning (Marshall, C.J.)
Concurrence (Ireland, J.)
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