Thomas v. Massachusetts Bay Transportation Authority

This case raises the question whether G. L. c. 161A, § 21, 1 the statute of limitations applicable to actions against the Massachusetts Bay Transportation Authority (MBTA), controls the time frame for commencement of actions of contract for personal injuries against the MBTA. We hold that § 21 governs actions of contract as well as tort for personal injuries sustained by a passenger of the MBTA.

While a passenger on an MBTA trolley car on March 19, 1979, the plaintiff suffered bodily injury. Almost three years later, on March 1, 1982, she commenced an action against the MBTA by filing a…