Gram v. Liberty Mutual Insurance

In Gram v. Liberty Mut. Ins. Co., 384 Mass. 659, 673 (1981) (Gram I), we remanded “the case for a determination of damages, measured by the amount of re*334newal commissions Gram reasonably could have expected to receive, reduced to reflect the proportion of his time that would reasonably have been expected to have been devoted to the servicing of those renewal policies.” We noted that “Gram has made no specific showing of his loss of any other identifiable, future benefit . . . reflective of past services to Liberty.” Id. We expressly stated that “[t]he amount of the renewal commissions…