Why this is correct — and what each of the five reasonable care cases decided:

Underwood v. Risman, 414 Mass. 96 (1993) — Established that a real estate broker owes a duty of reasonable care to prospective buyers. The SJC held that a broker who makes affirmative misrepresentations about a property's condition — or who fails to disclose known material information — may be held liable in tort and under Chapter 93A. This case is foundational to the broker's disclosure duty in Massachusetts.
Urman v. South Boston Savings Bank, 424 Mass. 165 (1998) — Addressed the disclosure obligations of an institutional seller (a bank) acting in a fiduciary capacity. The court examined whether the same reasonable care and disclosure standards that apply to licensed brokers extend to sellers who are financial institutions managing estate or foreclosure properties.
DeWolfe v. Hingham Centre Real Estate, 464 Mass. 795 (2013) — SJC 11168 — The SJC directly held that a listing broker who had actual knowledge of chronic water infiltration (a material defect) was obligated to disclose that defect to the buyer. Failure to do so constituted a breach of the duty of reasonable care and a violation of Chapter 93A. The decision reinforced that the seller's broker's duty of reasonable care runs not only to the seller but encompasses a broader obligation of honest dealing with buyers.
Quinlan v. Clasby, 71 Mass. App. Ct. 97 (2008) — The Appeals Court addressed broker liability arising from affirmative misrepresentations made about the physical condition of a property. The case explored the line between honest opinion and actionable misrepresentation, and affirmed that a broker who makes false statements of material fact about a property's condition is exposed to both negligence and Chapter 93A liability.
Piers v. Wheeler, 8 Mass. L. Rep. 410 (Mass. Super. 1998) — A Superior Court decision addressing the standard of reasonable care owed by a real estate agent with respect to known physical defects. The court applied the broker's duty of care in the context of a specific defect that was known to the broker but not communicated to the buyer.

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