Justia Massachusetts Supreme Court Opinion Summaries

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In 2011, Defendant pleaded guilty to possession of a class B substance. Defendant was sentenced to a one-year term of probation and the probation supervision fees and the victim-witness assessment. The Commonwealth entered a nolle prosequi on the underlying complaint after a judge granted Defendant’s motion to withdraw his guilty plea on the ground that Annie Dookhan, the discredited analyst at the William A. Hinton State Laboratory Institute at the center of misconduct allegations, performed the analysis of the substances seized during Defendant’s arrest. Thereafter, Defendant filed a motion for return of property, including probation supervision fees and the victim-witness assessment. The judge denied the motion. The Supreme Judicial Court affirmed, holding that there is no statutory basis for a refund of victim-witness assessments or probation fees where a defendant’s conviction is vacated after the withdrawal of a guilty plea. View "Commonwealth v. Martin" on Justia Law
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After a jury trial, Defendant was convicted of assault and battery on a family or household member in violation of Mass. Gen. Laws ch. 266, 13M(a). On appellate review, Defendant argued that the evidence was insufficient to support a conviction under the statute because he was not involved in a “substantive dating relationship” with the person he was charged with assaulting. The Supreme Judicial Court affirmed, holding that the evidence warranted a finding beyond a reasonable doubt that Defendant was involved in a “substantive dating relationship” with the person he was charged with assaulting, in violation of Mass. Gen. Laws ch. 265, 13M(c). View "Commonwealth v. Dustin" on Justia Law
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Clifford George and Jacquelyn George divorced in 2002. In 2013, Clifford filed a complaint seeking to modify his alimony obligation based on Mass. Gen. Laws ch. 208, 49(b), part of the Alimony Reform Act, which became effective nearly ten years after the parties’ divorce. Section 49(b) provides that general term alimony for certain marriages shall not continue for longer than seventy percent of the number of months of the marriage. A judge can deviate from the durational limit where doing so is required in the interests of justice, and the Act provides a schedule for when complaints for modification based on the new durational limits can be brought for alimony obligations that predated the effective date of the Act. The probate and family court judge denied Clifford’s complaint for modification, finding that deviation beyond the durational limits of the Act was warranted. The Supreme Judicial Court affirmed on other grounds, holding that Clifford’s complaint was filed prematurely. View "George v. George" on Justia Law
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Service Employees International Union, Local 509 (Union) brought a declaratory judgment action against the Department of Mental Health (DMH) maintaining that certain contracts DMH made with private vendors were “privatization contracts” subject to the requirements of the Pacheco Law. The Union sought a declaration invalidating the contracts because DMH did not comply with the statutory prerequisites of the Pacheco Law. The case was dismissed. The Supreme Judicial Court remanded the case. On remand, DMH again successfully moved to dismiss the Union’s declaratory judgment action on the basis that it was moot because the initial contracts had expired and the remaining extant renewal contracts were immune from challenge by virtue of Mass. Gen. Laws ch. 7, 53. The Union appealed, asserting that because the non-compliant initial contracts were invalid under Mass. Gen. Laws ch. 7, 54, so too were any renewal contracts made pursuant to them. The Supreme Judicial Court vacated the judgment of dismissal, holding that the protection afforded renewal contracts by section 53 is not extended to those renewal contracts made pursuant to timely challenged and subsequently invalidated privatization contracts under section 54. View "Service Employees International Union, Local 509 v. Department of Mental Health" on Justia Law

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In 1971, the City of Quincy, as trustee of the Adams Temple and School Fund (Adams Fund), sought a decree authorizing it to execute a proposed fifty-year lease of a building and parking lot of the Adams Academy that it had negotiated with the Quincy Historical Society (Society). In 1972, a single justice of the Supreme Judicial Court decreed that the City was authorized to execute the proposed lease. In 2014, the successor trustee of the Adams Fund (Plaintiff) filed a complaint seeking rescission of the lease and money damages, arguing that the City violated its fiduciary duty to the Woodward School for Girls, Inc., the sole income beneficiary of the Adams Fund, by executing the lease. Defendants, the City and the Society, moved for summary judgment, arguing that they were entitled to judgment under res judicata. The single justice allowed Defendants’ motion. Plaintiff appealed, contending that he should not be precluded by res judicata from obtaining relief because neither he nor the Woodward School was a party to the 1972 equity proceeding. The Supreme Judicial Court affirmed, holding that Plaintiff was precluded by res judicata from prevailing on his challenge to the execution of the lease. View "DeGiacomo v. City of Quincy" on Justia Law

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Petitioner was charged in three different indictments with three criminal offenses. Each of the cases were pending in the superior court where the court imposed a unified bail. The total bail in the three cases was $3,000. After Petitioner defaulted, the court revoked the previous order of bail and set a new unified bail in the amount of $13,000. The court then held a bail forfeiture hearing in which the court allowed forfeiture in one case. Petitioner forfeited $500 in that case. After the bail forfeiture, Petitioner filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 asking the county court to vacate the bail orders, release him, order his $500 to be returned, and dismiss all three superior court cases. The single justice denied relief with the exception of holding that once the default had been removed, the $500 in bail should not have been forfeited. The Supreme Judicial Court affirmed, holding that the single justice did not err in denying relief pursuant to Mass. Gen. Laws ch. 211, 3 and properly held that Petitioner may seek return of the forfeited bail in the superior court. View "Tavares v. Commonwealth" on Justia Law
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After a jury trial, Defendant was convicted of murder in the first degree on theories of extreme atrocity or cruelty and felony-murder. Defendant was also convicted of nine other charges, including home invasion while armed with a dangerous weapon. The Supreme Judicial Court (1) affirmed the conviction of murder in the first degree and declined to exercise its power under Mass. Gen. Laws ch. 278, 33E to reduce the degree of guilt or to order a new trial; but (2) reversed Defendant’s conviction with respect to the charge of home invasion, holding that the evidence was insufficient to support the conviction. View "Commonwealth v. Bois" on Justia Law
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In 2002, Defendant pleaded guilty to indecent assault and battery. In 2013, Defendant filed a motion to withdraw his guilty plea or for a new trial, arguing that his plea counsel was constitutionally ineffective by advising Defendant that he would need to “register” if he pleaded guilty to a sex offense without explaining the consequences of sex offender registration. The motion judge denied the motion, concluding that Defendant failed to establish that plea counsel was constitutionally ineffective. The Supreme Judicial Court affirmed, holding that plea counsel was not constitutionally ineffective in giving this advice in 2002, and the question of whether such advice would be constitutionally ineffective based on the current statutory scheme for sex offender registration is best left for another day. View "Commonwealth v. Sylvester" on Justia Law

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After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty and of home invasion. Defendant appealed, arguing, inter alia, that the evidence was insufficient as a matter of law to permit a rational jury to find beyond a reasonable doubt that he was criminal responsible at the time of the killing. The Supreme Judicial Court affirmed and declined to exercise its authority to order a new trial or to reduce the verdict of murder in the first degree, holding (1) the evidence was sufficient to permit a finding of criminal responsibility; (2) trial counsel did not provide ineffective assistance; (3) any impropriety in statements by the two prosecutors in their opening statement and closing argument was not prejudicial; and (4) the trial judge did not err in giving an instruction on the consequences of a verdict of not guilty by reason of lack of criminal responsibility. View "Commonwealth v. Griffin" on Justia Law
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The Massachusetts Insurers Insolvency Fund (Fund) is statutorily authorized to recover from “high net worth insureds” certain amounts paid by the Fund “on behalf of” such insureds. There was no dispute that defendant Berkshire Bank met the definition of “high net worth insured.” The Fund brought this action seeking to recover from Berkshire workers’ compensation benefits the Fund had paid to a Berkshire employee. The superior court allowed Berkshire’s motion for summary judgment, concluding that any amounts paid by the Fund would not be “on behalf of” the insured employer, and therefore, recoupment was not available. The Supreme Court reversed, holding that the Fund was authorized to recoup the sums in question because they were paid by the Fund “on behalf of” Berkshire within the meaning of Mass. Gen. Laws ch. 175D, 17(3). View "Massachusetts Insurers Insolvency Fund v. Berkshire Bank" on Justia Law