Justia Massachusetts Supreme Court Opinion Summaries

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Plaintiff, a high school student, was suspended from school for conduct that took place outside of school grounds. The suspension - which was mistakenly ordered on the ground that Plaintiff had been charged with a felony - lasted an entire semester, and Plaintiff was unable to graduate with her class. Plaintiff commenced this action asserting that her suspension was unlawful. The judge allowed Defendants’ motion to dismiss on the ground that Plaintiff failed to exhaust her administrative remedies under Mass. Gen. Laws ch. 72, 37H1/2 before filing her complaint. The Supreme Judicial Court reversed, holding that because the tort recovery a student may seek under Mass. Gen. Laws ch. 76, 16 provides a separate and distinct remedy from that available under section 37H1/2, Plaintiff was not obligated to exhaust the statute’s administrative remedies before pursuing a tort claim under Mass. Gen. Laws ch. 76, 16. View "Goodwin v. Lee Public Schools" on Justia Law

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In 2013, Defendant delivered his cellular telephone to his attorney for the purpose of seeking legal advice on several matters. In 2014, the Commonwealth filed a second motion for judicial approval of a grand jury subpoena to compel Defendant’s attorney to produce the cellular phone. The judge authorized the issuance of the subpoena, finding probable cause to believe that the telephone contained evidence of a crime under investigation by the grand jury. The Supreme Judicial Court reversed the judge’s order authorizing the issuance of a subpoena, holding that the attorney-client privilege protected Defendant against compelled production of the cellular telephone and that the protection afforded by the privilege could not be set aside based on a showing of probable cause. In 2016, the Commonwealth filed an application for an anticipatory search warrant pursuant to Mass. Gen. Laws ch. 276 1 to seize the telephone at the conclusion of a “legal advice period.” The superior court denied the application. The Supreme Judicial Court reversed, holding that a search warrant may issue for the seizure of the telephone because, absent such issuance, there is probable cause to believe that the telephone will be secreted from view. Remanded. View "Commonwealth v. Hernandez" on Justia Law
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After a jury trial, Defendant was convicted of rape of a child, incest, and related sex offenses. The Supreme Judicial Court vacated Defendant’s conviction for reckless endangerment and otherwise affirmed, holding (1) the trial judge erred in ruling that Defendant’s first complaint evidence relating to her defense that she was the victim of rape by the complainant was inadmissible as a matter of law, but Defendant was not prejudiced by the error; (2) the trial judge did not err in excluding a statement proffered as evidence of the victim’s state of mind; (3) there was insufficient evidence to prove reckless endangerment based on “serious bodily injury”; and (4) notwithstanding any impropriety in the prosecutor’s sentencing remarks, there was no basis to conclude that the judge was influenced by those remarks, and therefore, resentencing was not necessary. View "Commonwealth v. Mayotte" on Justia Law
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Mass. Gen. Laws ch. 148, 26I, the residential sprinkler provision, mandates the installation of automatic sprinklers in certain buildings. Plaintiff, the owner of two vacant apartment buildings that he intended to return to occupancy, argued that the rehabilitation he undertook to the buildings did not trigger the requirement that sprinklers be installed. The City of Holyoke’s fire chief ordered that automatic sprinkler systems be installed in each building. McLaurin then filed these complaints seeking relief in the nature of certiorari and declaratory, arguing that the orders were arbitrary and capricious. A judge of the Housing Court affirmed the chief’s orders. The Supreme Judicial Court vacated the judgment affirming the fire chief’s decision, holding that the Housing Court judge was not in a position to ascertain whether the decision was legally erroneous or arbitrary and capricious. Remanded to the fire chief for further proceedings. View "MacLaurin v. City of Holyoke" on Justia Law

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After a jury trial, Defendant was found guilty of murder in the first degree on a theory of deliberate premeditation and of the unlawful possession of a firearm. Defendant appealed, alleging error in (1) the denial of his motions to suppress certain evidence; (2) the denial of his motion for a new trial; and (3) the admission of certain evidence at trial. The Supreme Judicial Court affirmed, holding (1) the motion judge erred in denying Defendant’s motion to suppress certain evidence after Defendant failed to appear at the scheduled motion hearing, but the denial of the motion did not create a substantial likelihood of a miscarriage of justice; (2) the trial judge did not err in denying Defendant’s motion for a new trial after the jurors were exposed to extraneous material during deliberations; and (3) there was no error in the admission of certain evidence at Defendant’s trial. View "Commonwealth v. Miller" on Justia Law
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The Department of Public Utilities issued an order determining that the plain language of Mass. Gen. Laws ch. 164, 94A provides the Department with the statutory authority to review and approve ratepayer-backed, long-term contracts entered into by electric distribution companies for additional natural gas pipeline capacity in the Commonwealth. Plaintiffs filed separate petitions asking that the order be set aside on the ground that it was based on an erroneous interpretation of law. The Supreme Judicial Court vacated the Department’s order, holding (1) the order of the Department is a properly promulgated rule or regulation; but (2) the order is invalid in light of the statutory language and purpose of section 94A, as amended by the 1997 Restructuring Act, because it would undermine the main objectives of the Act. View "ENGIE Gas & LNG LLC v. Dep’t of Pub. Utils." on Justia Law

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Defendant, who was admitted to the United States as a lawful permanent resident alien, pleaded guilty to an indictment alleging larceny of a motor vehicle. Defendant later moved to withdraw the guilty plea and vacate the conviction, arguing that the judge accepted his plea without advising him that the guilty plea might have the consequences of exclusion from admission to the United States. The judge denied the motion. The Appellate Court affirmed, concluding (1) the Commonwealth failed to prove that Defendant received the required warning regarding exclusion from admission to the United States; but (2) Defendant failed to show that he faced the consequence of exclusion. The Supreme Judicial Court vacated Defendant’s conviction, holding (1) a defendant satisfies the burden of showing that his conviction may have the consequences of exclusion from admission to the United States by showing that he has a bona fide desire to leave the country and reenter and that, if he were to do so, there would be a substantial risk that he would be excluded from admission because of his conviction; and (2) Defendant here met this burden, and because Defendant was not warned of this consequence during his plea colloquy, his conviction must be vacated. View "Commonwealth v. Valdez" on Justia Law

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Defendant was arrested for operating while under the influence of intoxicating liquor. Defendant was not given an opportunity to consult with counsel before being required to decide whether to submit to a breathalyzer test. Defendant moved to suppress the results of the breathalyzer test, arguing that she had a right to counsel before deciding whether to submit to the breathalyzer test. After an evidentiary hearing, the district court reported a question of law asking whether the 2003 amendment to Mass. Gen. Laws ch. 90, 24, the statute establishing the offense of driving while under the influence of intoxicating liquor, now makes the decision by a defendant whether or not to take a breath test is a critical stage of the criminal proceedings requiring that the defendant be advised of his or her right to counsel prior to making that decision. The Supreme Judicial Court answered the reported question in the negative, holding that there is no right to counsel under the Sixth Amendment to the United States Constitution or article 12 of the Massachusetts Declaration of Rights before a defendant decides whether to submit to a breathalyzer test. View "Commonwealth v. Neary-French" on Justia Law

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In Suffolk I, the Supreme Judicial Court held that Reading Co-Operative Bank (Bank) was allowed to require Suffolk Construction Company, Inc. (Suffolk) to perform fully Suffolk’s obligations pursuant to a collateral assignment of payments under a subcontract between Suffolk and Benchmark Mechanical Systems, Inc. (Benchmark) to secure a debt owed by Bankmark to the Bank. Suffolk subsequently commenced this action to recover the surplus that resulted when the Bank applied that collateral to satisfy Benchmark’s debt. Suffolk’s equitable claims for implied subrogation and implied indemnification were dismissed for failure to state a claim, and Suffolk’s common-law claims were dismissed as time-barred. The Supreme Judicial Court affirmed in part and reversed in part, holding (1) Suffolk’s common-law claims were time-barred; but (2) Suffolk stated viable equitable claims to prevent Benchmark’s potential windfall and unjust enrichment for which relief can be granted. View "Suffolk Constr. Co., Inc. v. Benchmark Mechanical Sys., Inc." on Justia Law
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After a jury trial, Defendant was convicted of armed robbery while masked. The trial judge granted Defendant’s motion for a mistrial, determining that a series of the prosecutor’s statements made during closing argument constituted prejudicial error. The Commonwealth appealed, arguing that, although an order granting a mistrial is generally not appealable, the Supreme Judicial Court had jurisdiction to hear the appeal because the motion was granted after the verdict and thus was equivalent to a motion for relief from a guilty verdict under the Massachusetts Rules of Criminal Procedure. The Supreme Judicial Court dismissed the appeal, holding that the trial judge’s order granting Defendant’s motion for a mistrial was not appealable. View "Commonwealth v. Brangan" on Justia Law
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