Justia Massachusetts Supreme Court Opinion Summaries

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In a dispute between tenured faculty members and Tufts University, the faculty members alleged that the university's policies requiring them to cover half of their salary with external research funding and reducing their laboratory space violated their tenure rights to economic security and academic freedom. These policies, instituted between 2016 and 2019, led to a decrease in the plaintiffs' salaries and full-time status, and their laboratory space was reduced or closed entirely when they failed to meet the external funding requirements.The Supreme Judicial Court of Massachusetts noted that tenure contracts are defined by their specific terms and must be understood in the context of the academic community's norms and expectations. The court found that the term "economic security" in the tenure contracts was ambiguous and further evidence was needed to determine whether the reductions in salary and full-time status violated the economic security provided in the tenure contracts. However, the court concluded that neither economic security nor academic freedom guaranteed the plaintiffs specific lab space.The court reversed the lower court's judgment in favor of Tufts on the compensation policies, remanding the case for further proceedings. However, it affirmed the lower court's judgment that the laboratory space guidelines did not violate the plaintiffs' tenure rights. The court also left unresolved the plaintiffs' claims under the Wage Act, as it was dependent on the outcome of the compensation dispute. View "Wortis v. Trustees of Tufts College" on Justia Law

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The case revolves around a defendant convicted of severe, racially motivated violence, who sought to stay the execution of his sentence pending appeal. The defendant, a dual citizen of the U.S. and Morocco, with frequent travel to Morocco, was deemed a flight risk and a danger to others by the trial judge and a single justice of the Appeals Court. While the defendant demonstrated a likelihood of success on his appeal, the single justice upheld the trial judge's decision, citing the defendant's regular travels abroad, the serious nature of his crimes, and the significant sentence he faced as reasons for his potential flight risk. Following the denial of his stay, the defendant appealed to the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court affirmed the lower courts' decisions. The court found that the defendant's likelihood of success on appeal did not mitigate the identified security risk. The court ruled that the likelihood of success on appeal and the potential security risk are two distinct factors to consider, and one does not influence the other. The court concluded that the single justice's decision was not outside the range of reasonable alternatives, thus not an abuse of discretion. Therefore, the Supreme Judicial Court upheld the denial of the defendant's motion to stay his sentence pending appeal. View "Commonwealth v. Kalila" on Justia Law

Posted in: Criminal Law
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In 2018, the Massachusetts Legislature enacted the "Tobacco Act," which prohibited the sale of tobacco products to anyone under 21 years old. The town of Brookline later passed an ordinance that divided potential tobacco consumers into two groups based on birth year: those born before January 1, 2000, and those born on or after that date. Retailers could sell tobacco products to the first group, but not the second. This effectively created an incremental prohibition on the sale of tobacco products in the town. Several retailers filed a lawsuit, claiming that the local law was preempted by the Tobacco Act and violated the equal protection provisions of the Massachusetts Constitution.The Massachusetts Supreme Judicial Court held that the local law was not preempted by the Tobacco Act. The court reasoned that the Tobacco Act expressly permitted local communities to limit and ban the sale of tobacco products. Furthermore, the local law did not conflict with the Tobacco Act's prohibition on sales to persons under 21; instead, it augmented this prohibition by further limiting access to tobacco products.The court also held that the local law did not violate the equal protection guarantees of the state constitution. The court found that the birthdate classification in the local law was rationally related to the town's legitimate interest in mitigating tobacco use, especially among minors. The court affirmed the dismissal of the retailers' complaint. View "Six Brothers, Inc. v. Town of Brookline" on Justia Law

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The court examined a case involving a divorcing couple, Amy Sue Openshaw and Glen Romney Openshaw, who had a custom of regularly saving a portion of their income throughout their marriage. The husband contested the judge’s alimony decision, arguing that the judge should not have considered the couple's practice of saving as part of the marital lifestyle in setting the amount of alimony.The court held that where a couple has a customary practice of saving during the marriage, such saving can be considered as a component of the couple's marital lifestyle in determining alimony. Therefore, the judge did not err in considering the parties' regular savings practice in setting the alimony amount.The husband also disputed the division of liabilities, as the judge assigned the wife only $5,032 in liabilities, while the husband was assigned $343,280, primarily for the family's unpaid tax debt. The court found the division of liabilities to be erroneous as the judge did not explain why the tax debt, a significant marital liability, was assigned solely to the husband. The court ordered a remand to reevaluate the division of liabilities in the judgment. View "Openshaw v. Openshaw" on Justia Law

Posted in: Family Law, Tax Law
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In this case, the plaintiff, Fallon Community Health Plan, Inc., adopted a policy requiring its employees to be vaccinated against COVID-19. The defendant, Shanika Jefferson, a home health aide employed by Fallon, sought a religious exemption from the vaccination requirement. Her request was denied, and her employment was terminated. Jefferson then applied for and was approved for unemployment benefits from the Department of Unemployment Assistance. However, Fallon contended that Jefferson was ineligible for the benefits and sought review of the decision. The board of review of the department, as well as a District Court judge, affirmed the decision.Fallon argued that Jefferson was disqualified from receiving unemployment benefits as per § 25 (e) (2) of General Laws c. 151A because she refused the COVID-19 vaccine in knowing violation of Fallon's reasonable policy and in wilful disregard of Fallon's interest in keeping its vulnerable patient population healthy. However, the Supreme Judicial Court disagreed with Fallon's contention. The court held that Jefferson did not engage in "deliberate misconduct", but rather made a good faith effort to comply with Fallon's policy by applying for a religious exemption. The court also found that Fallon failed to demonstrate that Jefferson should be disqualified on the basis of a "knowing violation" of that policy. The court considered the unique circumstances of the case, including Jefferson's sincere religious beliefs, which did not present her with a meaningful choice regarding vaccination. Therefore, the Supreme Judicial Court affirmed the decision of the lower courts, allowing Jefferson to receive unemployment benefits. View "Fallon Community Health Plan, Inc. v. Acting Director of the Department of Unemployment Assistance" on Justia Law

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The dispute arose from an agreement between Columbia Plaza Associates (CPA) and Northeastern University regarding the development of a parcel of land in Boston. The contract stipulated that the developer for each phase of the project would be Northeastern or an affiliated entity, which could include CPA. The contract also specified that the developer of the garage parcel would be a joint venture between Northeastern and CPA.CPA claimed that Northeastern violated the agreement when it sought to develop a subparcel unilaterally and repudiated CPA's rights to that subparcel. CPA also argued that Northeastern's communication with a governmental agency amounted to a deceptive business practice.The court held that the agreement did not grant CPA development rights in any of the subparcels except for the garage parcel. The court also found no proof of an enforceable promise by Northeastern to build a hotel with CPA on the disputed subparcel. The court thus ruled in favor of Northeastern on all counts, including CPA's claims for breach of contract, breach of the implied covenant of good faith and fair dealing, intentional interference with advantageous economic relations, unjust enrichment, commercial fraud, unfair or deceptive business practices, and requests for declaratory and injunctive relief.The court further held that Northeastern was entitled to attorney's fees under the anti-SLAPP statute because it successfully dismissed CPA's claim of commercial fraud, which was based solely on Northeastern's petitioning activity. The court did not find CPA's claim to be a SLAPP suit. View "Columbia Plaza Associates v. Northeastern University" on Justia Law

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In a complex commercial dispute with a series of administrative and legal challenges, the Supreme Judicial Court of Massachusetts found that the defendants, Bristol Asphalt Co., Inc. and others, did not meet the criteria to dismiss the case under the "anti-SLAPP" statute. The court outlined a simplified framework for considering anti-SLAPP motions, returning to the traditional approach set out in Duracraft Corp. v. Holmes Prods. Corp. The court also clarified that the appropriate standard of review for a ruling on a special motion to dismiss is de novo, rather than for an abuse of discretion.The dispute arose from the plaintiffs' efforts to open an asphalt plant in the same industrial zone as the existing plant owned by the defendants. The defendants launched a series of administrative and legal challenges to the plaintiffs’ efforts to obtain regulatory approval for the construction and operation of the proposed plant. The plaintiffs filed a three-count complaint alleging that the defendants' legal challenges constituted unfair or deceptive acts or practices, conspiracy in restraint of trade, and abuse of process. In response, the defendants filed a special motion to dismiss under the anti-SLAPP statute.The Supreme Judicial Court affirmed the lower court's denial of the defendants' special motion to dismiss, concluding that the defendants' petitioning activities were not entitled to the procedural protections of the anti-SLAPP statute. The court found that the defendants' challenges to the plaintiffs' proposed asphalt plant did not lack any reasonable factual support or arguable legal basis. Therefore, the plaintiffs' claims against the defendants were not based solely on the defendants' petitioning activities and were not subject to dismissal under the anti-SLAPP statute. View "Bristol Asphalt, Co., Inc. v. Rochester Bituminous Products, Inc." on Justia Law

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In the case of Commonwealth v. Rashad Shepherd, the Supreme Judicial Court of Massachusetts affirmed the defendant’s conviction of murder in the first degree on the theory of felony-murder, with attempted unarmed robbery as the predicate felony. The case centered around a failed robbery attempt that ended in the shooting and death of the intended victim. The defendant, along with two co-conspirators, hatched a plan to rob the victim, who was known to sell marijuana from his apartment. However, when the plan was put into motion, the victim resisted, and in the ensuing altercation, was shot and killed. The prosecution's theory was that the defendant was the shooter.In his appeal, the defendant argued that the court’s decision in a prior case, Commonwealth v. Brown, which abolished felony-murder as an independent theory of liability for murder in the first and second degrees, should be applied to his case retroactively. He maintained that not doing so violated equal protection principles as more Black individuals were serving life sentences without parole for felony-murder than white individuals. However, the court rejected this argument, noting that the decision in Brown was applied to all equally, regardless of race or ethnicity.The defendant also claimed errors in jury instructions and conduct by the trial judge, but the court determined that there was no reversible error. Lastly, the defendant argued that he received ineffective assistance of counsel, but the court found that the decisions by the defense were not manifestly unreasonable. View "Commonwealth v. Shepherd" on Justia Law

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In the case before the Supreme Judicial Court of Massachusetts, the defendant, William J. Camuti, was convicted of murder in the first degree for poisoning his friend and business associate, Stephen Rakes, with potassium cyanide. Several years after his conviction, Camuti filed a postconviction motion for forensic testing of the shirt that Rakes was wearing when his body was found, claiming that DNA testing of the shirt could potentially provide evidence that could exonerate him. However, a Superior Court judge denied the motion, finding that Camuti had failed to meet his burden under G. L. c. 278A, § 7 (b), to demonstrate that a reasonably effective defense attorney would have sought to test Rakes' shirt for DNA.On appeal, the Supreme Judicial Court affirmed the lower court's decision. The court reasoned that the absence of trace evidence, including DNA evidence, was a central part of Camuti's defense strategy at trial. His counsel had repeatedly emphasized the lack of physical evidence linking Camuti to the crime scene, and the introduction of DNA evidence from Rakes' shirt could have undermined this defense. The court further noted that even if DNA testing had revealed the presence of a third party's DNA on the shirt, this would have had minimal exculpatory value given the circumstances of the case. Given these considerations, the court concluded that a reasonably effective attorney would not have sought DNA testing of Rakes' shirt. Therefore, Camuti had not met his burden under G. L. c. 278A, § 7 (b), and the denial of his postconviction motion for forensic testing was affirmed. View "Commonwealth v. Camuti" on Justia Law

Posted in: Criminal Law
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The case involves the Commonwealth's appeal against the trial judge's denial of its motion to admit expert testimony on Frequent Location History (FLH) data retrieved from the defendant's cell phone in a murder case. The Commonwealth argued that the FLH data would corroborate its witness's testimony, placing the defendant at the crime scene. The trial judge denied the motion, stating that the Commonwealth had not met its burden of showing that FLH data had been generally accepted as reliable by the scientific community. The judge also found that the Commonwealth had failed to provide evidence that FLH data has been subjected to peer review or publication, has an unacceptably high known or potential rate of error, and is governed by recognized standards. The Supreme Judicial Court for the county of Suffolk agreed with the trial judge's decision, concluding that the Commonwealth had not shown that FLH data is reliable. Therefore, the court affirmed the trial judge's denial of the Commonwealth's motion to admit the FLH data. View "Commonwealth v. Arrington" on Justia Law

Posted in: Criminal Law