Brief Fact Summary. Plaintiff companies, Salmanor and Atlantic Salmon, attempted to hold Defendant, Michael Curran, personally liable for balances due to Plaintiffs.
Synopsis of Rule of Law. An agent can be held personally liable for actions on behalf of the principal if the agent does not disclose the principal.
Issue. The issue is whether an agent can be held personally liable if he does not disclose the principal to the other party.
Held. Defendant is personally liable for the actions purportedly performed on behalf of a principal. It is the duty of the agent to inform the other party who the actual principal is, or else the agent is liable.
Discussion. The Appeals Court of Massachusetts, Suffolk, was hesitant to accept that there was a principal other than Defendant. However, the courts holding made the question irrelevant. The holding is in direct contrast with Watteau v. Fenwick.