Justia Massachusetts Supreme Court Opinion Summaries

By
Under Mass. Gen. Laws ch. 63, corporations that generate business income in the Commonwealth and other states must pay taxes on that income according to an apportionment formula that seeks to tax the corporation’s income generated in Massachusetts. For a “manufacturing corporation,” the statutory formula is based solely on the corporation’s sales. The Appellate Tax Board determined that Genentech, Inc., a Delaware corporation with a principal place of business in California that earns business income in the Commonwealth, qualified as a manufacturing corporation for the tax years 1998 through 2004. On appeal, Genentech appealed that determination, among other things. The Supreme Judicial Court affirmed, holding (1) Genentech qualified in each of the tax years at issue as a “manufacturing corporation” as defined in Mass. Gen. Laws ch. 63, 38(1)(1) and, under section 38(1)(2), was required to apportion its income under the single-factor formula using solely the statute’s sales factor; and (2) the Board properly rejected Genentech’s claim that application of the statute’s single-factor apportionment formula based on sales to the company violated the Commerce Clause of the federal Constitution. View "Genentech, Inc. v. Commissioner of Revenue" on Justia Law

By
Defendant, an inmate, was charged with falsely reporting a sexual assault to a deputy sheriff employed at the corrections facility. After a jury-waived trial, Defendant was convicted of making a false report of a crime to a police officer. Defendant appealed, arguing that a deputy sheriff is not a police officer within the meaning of Mass. Gen. Laws ch. 269, 13A, and therefore, the evidence was insufficient to sustain the conviction. The Supreme Judicial Court reversed, holding that a deputy sheriff is not a “police officer” within the meaning of the statute. View "Commonwealth v. Gernrich" on Justia Law
By
Posted in:
Updated:

By
In 2012, the Boston Municipal Court issued a criminal complaint charging Defendant, who was mentally ill, with assault and battery by means of a dangerous weapon. Defendant has been in custody ever since, but each time the scheduled date approached, the trial was continued or else Defendant was found to be incompetent. Defendant unsuccessfully sought dismissal of the charge pursuant to Mass. Gen. Laws ch. 123, 16(f), under which a defendant who is found incompetent to stand trial is entitled to dismissal of the charge against him corresponding to one-half the maximum sentence the defendant could have received if convicted of the most serious crime with which he was charged. Defendant filed a petition for relief under Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court denied relief, holding (1) under section 16(f), the basis for the calculation of the date of dismissal is the maximum sentence provided for in the statute, regardless of the court in which the charges are pending; but (2) in this case, dismissal of the charge before the computed date may nevertheless be appropriate in the interest of justice. Remanded. View "Commonwealth v. Calvaire" on Justia Law
By
Posted in:
Updated:

By
After a jury-waived trial, Defendant was convicted of various firearm charges. On appeal, Defendant challenged the denial of his motion to suppress the firearm, asserting that police officers lacked reasonable suspicion to stop him to investigate a report of shots fired at a vehicle. The Appeals Court affirmed. The Supreme Judicial court vacated the conviction and remanded for a new trial, holding that the motion judge erred in denying the motion to suppress because, assessing the totality of the circumstances leading to the stop of Defendant, the facts known to the police at the time of the seizure were not sufficient to establish reasonable suspicion that Defendant was connected to the alleged shooting at the vehicle. View "Commonwealth v. Meneus" on Justia Law

By
After a jury trial, Defendant was convicted of possession of cocaine with intent to distribute. The Appeals Court affirmed. Defendant appealed, arguing that the admission into evidence of expert testimony opining as to the typical physical characteristics of “crack” cocaine addicts was inadmissible “negative profiling” evidence. The Supreme Judicial Court agreed with Defendant and vacated the judgment, holding (1) the trial court erred in admitting the expert’s testimony concerning the physical characteristics of crack cocaine addictions; and (2) the error created a substantial risk of a miscarriage of justice. Remanded for further proceedings. View "Commonwealth v. Horne" on Justia Law
By
Posted in:
Updated:

By
In 1993, Joan Oggiani, a judicial secretary, was designated as the deputy assistant register when that position was created. In 2015, the register requested approval to remove Aggiani’s designation. The Chief Justice of the Probate and Family Court approved the register’s request. Oggiani requested review, but Oggiani was told that the decision was final. Oggiani then filed a petition for relief under Mass. Gen. Laws ch. 217, 29D. The county court denied relief. The Supreme Judicial Court affirmed, holding that the single justice did not abuse his discretion or commit an error of law by denying Oggiani’s petition for relief under the circumstances. View "Oggiani v. Chief Justice of the Trial Court" on Justia Law
By
Posted in:
Updated:

By
After a jury trial, Defendant was convicted of murder in the second degree and assault and battery by means of a dangerous weapon. Defendant appealed, arguing that, based on the evidence presented at trial and the prosecutor’s closing argument, the judge erred in denying his motion for a required finding of not guilty and denying his motion to reduce the verdict to a conviction of manslaughter. The Supreme Judicial Court held (1) there was sufficient evidence to convict Defendant of murder in the second degree; (2) the prosecutor’s closing argument was not improper; and (3) because the trial judge did not state his reasons for denying Defendant’s motion to reduce the verdict and because the trial judge has since become a member of the Supreme Judicial Court, the part of the case regarding the motion to reduce the verdict is transferred to the county court to review anew Defendant’s motion. View "Commonwealth v. Grassie" on Justia Law
By
Posted in:
Updated:

By
Defendant was watching a feature in an “unsolved crime” series news broadcast with his girl friend’s mother when he told her he had been the shooter in the surveillance footage showing the suspect that was aired in the broadcast. During Defendant’s trial, the superior court judge allowed into evidence a redacted version of the news broadcast. Defendant was ultimately convicted of murder in the first degree on a theory of deliberate premeditation. Defendant’s principal argument on appeal was that the news broadcast should not have been admitted into evidence or, alternatively, that it should have been more heavily redacted. The Supreme Judicial Court affirmed the conviction, holding (1) the trial judge did not err in allowing admission of the news broadcast; and (2) there was no error requiring reversal in Defendant’s other challenges. View "Commonwealth v. Martinez" on Justia Law
By
Posted in:
Updated:

By
Defendant was charged with murder in the first degree. Defendant filed a motion to suppress statements he made at two police stations, arguing that he did not knowingly and intelligently waive his Miranda rights and that the statements were not made voluntarily. Defendant then moved to impound a video recording and transcript of a police interview with Defendant that was the subject of the motion to suppress and that was subsequently suppressed. A superior court judge orally denied the motion to impound. A single justice of the Appeals Court denied Defendant’s request for interlocutory relief. A single justice of the Supreme Judicial Court vacated the denial of the motion to impound, concluding that the single justice committed an error of law and abused his discretion in affirming the judge’s denial of the motion to impound. The Supreme Judicial Court affirmed the motion judge's denial of the motion to impound, holding (1) the motion judge applied the correct legal standard in deciding Defendant’s motion to impound; and (2) the motion judge did not abuse his discretion in denying the motion to impound. View "Commonwealth v. Chism" on Justia Law

By
The school zone statute punishes individuals who commit certain enumerated drug offenses within 300 feet of a school or 100 feet of a public park or playground. Defendant was a passenger in a motor vehicle that was driven on a public roadway past a public park and stopped at a red light. When the light turned green, law enforcement officers stopped the vehicle, at which point the vehicle was no longer within 100 feet of the public park. The officers searched the vehicle and found drugs and a firearm. Defendant was arrested and charged with a number of offenses, including committing a drug offense within one hundred feet of a public park, in violation of Mass. Gen. Laws ch. 94C, 32J. Defendant moved to dismiss the park zone charge, arguing that the school zone statute is unconstitutional as applied to him. The judge allowed the motion. The Supreme Court affirmed, holding that application of Mass. Gen. Laws ch. 94C, 32J to Defendant, under the facts and circumstances of this case, would be overreaching. View "Commonwealth v. Peterson" on Justia Law