Justia Massachusetts Supreme Court Opinion Summaries

Plaintiff, an inmate at a correctional center, was held in administrative segregation in center's special management unit (SMU) on awaiting action status as prison officials sought his transfer or reclassification. During that time, Plaintiff's detainment was given the informal review provided by the Department of Correction (DOC) regulations that govern detention of inmates in an SMU. Claiming that he was entitled the review procedures provided by regulation to inmates housed in a departmental segregation unit, Plaintiff brought suit alleging violations of his constitutional due process rights and of various state statutes and regulations, and seeking declaratory and injunctive relief as well as money damages. The superior court granted Plaintiff's partial motion for summary judgment, ruling that Defendants had violated his right to due process. The judge denied Defendants' cross motion for summary judgment insofar as it sought to dismiss Plaintiff's claims as barred under the doctrine of qualified immunity for public officials. The Supreme Court held (1) Plaintiff's administrative segregation was unlawful, but (2) the law in this regard was not clearly established at the time of the underlying events, and with respect to Plaintiff's claim for damages, Defendants were entitled to summary judgment on the basis of qualified immunity. View "LaChance v. Comm'r of Corr." on Justia Law

Plaintiff Creative Playthings Ltd., a Massachusetts corporation, entered into a franchising agreement with Defendant under which Defendant agreed to operate a Creative Playthings franchise store in Florida. Plaintiff later terminated its agreement with Defendant and commenced this action against Defendant in the U.S. district court for breach of contract and associated claims. Defendant filed several counterclaims against Creative. Creative moved for summary judgment on Defendant's counterclaims, asserting they were time barred under the limitations provision in the franchise agreement. The federal district court judge declined to decide Creative's motion and instead certified the question of whether contractually shortened statutes of limitations are generally enforceable under Massachusetts law. The Supreme Court answered by holding that, in a franchise agreement governed by Massachusetts law, a limitations period in the contract shortening the time within which claims must be brought is valid and enforceable under Massachusetts law if the claim arises under the contract and the agreed-upon limitations period is subject to negotiation by the parties, is not otherwise limited by controlling statute, is reasonable, is not a statute of repose, and is not contrary to public policy. View "Creative Playthings Franchising Corp. v. Reiser" on Justia Law

Defendant was indicted for possession with intent to distribute heroin and for possession with intent to distribute heroin, subsequent offense. The charges resulted from the execution of a search warrant at Defendant's home. The affidavit submitted in support of the search warrant application stated that the police had conducted four controlled drug purchases from Defendant and referred to five different confidential informants. Defendant filed a motion for disclosure of the identity of one of the informants, stating she believed the informant was John Smith and that she intended to raise an entrapment defense at trial. The judge who acted on the motion ordered that the Commonwealth confirm or deny whether the informant was Smith. The Commonwealth filed a petition seeking relief from the order, which a single justice denied. The Supreme Court affirmed and ordered the Commonwealth to comply with the order forthwith. View "Commonwealth v. Elias" on Justia Law

Defendant was classified by the sex offender registry board as a level two sex offender. Defendant subsequently registered with the police department. When Defendant failed to register again a few months later during the month of his birth, he was charged with a single count of failing to register as a sex offender in violation of Mass. Gen. Laws ch. 6, 178F 1/2. Defendant pled guilty to the offense and later filed a motion to withdraw the guilty plea. His motion was denied. The Supreme Court reversed, holding (1) although Defendant admitted during the plea hearing that he did not register in his birth month, the statute did not require him to do so; and (2) being under no obligation to register in his birth month, Defendant could not be convicted of the offense of failure to register. View "Commonwealth v. Loring" on Justia Law

A superior court jury convicted Defendant of murder in the first degree on a theory of deliberate premeditation, and of two firearms offenses. On appeal, Defendant claimed error in a number of respects. The Supreme Court reversed Defendant's convictions, set the verdicts aside, and remanded for a new trial, holding (1) it was clear error to preclude Defendant's use of an unavailable witness's grand jury testimony, as requested, for impeachment purposes, and the error was not harmless beyond a reasonable doubt; (2) the admission of certain photographs into evidence was prejudicial error; and (3) the introduction of a rap video as evidence of Defendant's gang membership was prejudicial error. View "Commonwealth v. Gray" on Justia Law

Based on an informant's tip, as well as police observation of three controlled drug purchases and additional surveillance, police obtained a warrant to search Defendant's apartment. They found a firearm and significant quantities of heroin and cocaine. On this basis, Defendant was charged with various drug and firearm offenses. Defendant moved to suppress the contraband as the fruit of an unlawful search of her apartment. Defendant appealed, claiming in relevant part that the affidavit supporting the search warrant was insufficient to establish probable cause to believe that drugs would be found in her residence because the information in the affidavit did not prove an adequate "nexus" between her drug sales and her residence. A superior court judge agreed and allowed the motion to suppress. The Supreme Court reversed the order allowing Defendant's motion to suppress the contraband, holding that the affidavit supporting the search warrant established a sufficient nexus to Defendant's apartment to support a finding of probable cause that contraband related to drug sales would be found in the location searched. View "Commonwealth v. Tapia" on Justia Law

In an underlying care and protection case in the juvenile court, following a seventy-two hour hearing, the judge granted temporary custody of a child to the Department of Children and Families. The child's mother filed a Mass. Gen. Laws ch. 211, 3 petition seeking relief from that order. A single justice of the Supreme Court summarily denied the petition without a hearing and without addressing the substantive merits of the mother's claims. The mother appealed. The Supreme Court affirmed, holding that there was no error or abuse of discretion in the single justice's declining to exercise the court's extraordinary power of general superintendence to disturb the juvenile court judge's ruling. View "In re Danielle" on Justia Law

The named Plaintiffs, African-American and Hispanic police officers, brought suit on behalf of themselves and a class of similarly situated individuals against Defendants, the Commonwealth and the division of human resources, alleging that the division engaged in racial discrimination through the creation and administration of an examination for candidates seeking promotion to the position of police sergeant. A superior court judge granted Defendants' motion to dismiss on the grounds that the Commonwealth had not waived its sovereign immunity from suit and, in the alternative, that Plaintiffs had failed to state any claim on which relief could be granted. The Supreme Court concluded (1) Plaintiffs' claim under Mass. Gen. Laws ch. 151B, 4(4A) should not have been dismissed because it alleged adequately that Defendants interfered with Plaintiffs' right to be free of racial discrimination in opportunities for promotion; but (2) the remainder of Plaintiffs' claims were properly dismissed. View "Lopez v. Commonwealth" on Justia Law

Plaintiff sought employment as a police officer with the Boston police department. On three occasions, the department extended conditional offers of appointment to Plaintiff, each of which was contingent upon her successful completion of a psychological screening process. On each occasion, department psychiatrists found Plaintiff psychologically unqualified for the job and bypassed her for appointment as a police officer. The civil service commission concluded that the department failed to meet its burden of establishing a reasonable justification for bypassing Plaintiff and ordered that her name be restored to the department's list of individuals certified for appointment. The superior court vacated the commission's order. The Supreme Court reversed, holding (1) the superior court correctly found that the commission erred in the manner in which it considered expert testimony from another proceeding; but (2) because the commission's decision was supported by substantial evidence independent of this extraneous evidence, the error did not prejudice the department. View "Boston Police Dep't v. Kavaleski" on Justia Law

Defendant was convicted by a jury of murder in the first degree on a theory of deliberate premeditation in the stabbing death of her boyfriend. Defendant appealed from both her conviction and the denial of her motion for a new trial. The Supreme Court reversed Defendant's conviction and remanded the matter for a new trial because (1) on multiple occasions, over objection, the trial judge erroneously allowed the Commonwealth to introduce highly prejudicial evidence of Defendant's prior bad acts; and (2) the judge later declined to provide an instruction as to the excessive use of force in self-defense that was supported by the evidence. View "Commonwealth v. Anestal" on Justia Law