Justia Massachusetts Supreme Court Opinion Summaries

Defendant was convicted of various sexual offenses and sentenced to a term of imprisonment. Prior to Defendant's scheduled release, the Commonwealth sought to commit Defendant as a sexually dangerous person. Defendant was temporarily committed and stipulated to probable cause. The Commonwealth subsequently filed a timely petition for trial. Defendant moved to dismiss the petition on the basis that the trial had not commenced within sixty days. The trial court denied the motion. The Supreme Court affirmed, holding that Defendant was not entitled as a matter of right to interlocutory relief because he had an adequate alternative remedy by way of an appeal. View "Flood v. Commonwealth" on Justia Law

Defendant filed this action against the Massachusetts Trial Court, alleging that it violated Mass. Gen. Laws ch. 151B by not selecting Defendant for two different promotions based on her age. A jury found in Defendant's favor with respect to one of the two positions. The trial judge then denied Defendant's motion for judgment notwithstanding the verdict but granted its motion for a new trial. Both parties appealed. The appeals court reversed the denial of the motion for judgment notwithstanding the verdict and vacated the order allowing the motion for a new trial. The Supreme Court remanded the case to the superior court, holding that because the judge granted the motion for a new trial, the appeal was premature, and the case should not have proceeded to an appellate court. View "Zaniboni v. Mass. Trial Court" on Justia Law

Plaintiff, a janitorial cleaning services franchisee, along with franchisees from other states, filed a putative class action in the U.S. district court against Defendant, the Massachusetts corporation that franchised Plaintiff's business, alleging that Defendant misclassified him as an independent contractor and committed various wage law violations. The district court certified several questions of law to the Massachusetts Supreme Court, which answered by holding (1) a plaintiff's failure to exhaust administrative remedies pursuant to Mass. Gen. Laws ch. 150 by filing a complaint with the attorney general does not deprive a court of jurisdiction to consider Plaintiff's claims under Mass. Gen. Laws ch. 149, 148, 148B, 150, and 151(1) and (1a); (2) a franchisor is vicariously liable for the conduct of its franchisee only where the franchisor controls or has a right to control the specific policy or practice resulting in harm to the franchisee; and (3) a defendant may be liable for employee misclassification where there was no contract for service between the plaintiff and the defendant. View "Depianti v. Jan-Pro Franchising Int'l, Inc." on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of felony-murder and unlawful possession of a firearm. Defendant and Joseph Morgan were tried separately for the crimes. The Supreme Court affirmed Defendant's convictions, holding that the trial judge (1) properly admitted the victim's statements to the 911 operator because the statements were excited utterances and were nontestimonial insofar as they were solicited for the primary purpose of enabling the police to assist in an ongoing emergency; (2) properly admitted the victim's statements to a responding police officer as dying declarations, concluding that the statements were not subject to the constraints of the confrontation clause; (3) did not err in declining to apply the doctrine of judicial estoppel to preclude the Commonwealth from arguing that the victim's intoxication did not affect his ability to identify Defendant as one of the shooters where the Commonwealth had previously argued at Morgan's trial that the victim's identification of Morgan had been unreliable because the positions taken by the Commonwealth at the two trials with respect to the reliability of the victim's identifications were distinct and not mutually exclusive. View "Commonwealth v. Middlemiss" on Justia Law

Defendant was incited for murder in the first degree and various counts of masked armed robbery. Pursuant to Mass. R. Crim. P. 14(b)(2), Defendant notified the Commonwealth that he intended to offer expert testimony concerning his mental state at the time of the alleged crime. The Commonwealth subsequently moved for a court-ordered psychiatric examination of Defendant, requesting disclosure of the custodians of Defendant's medical and psychiatric records and production and seeking the production of all such treatment records to the court. The motion judge denied the portion of the motion requesting disclosure of the custodians and production of Defendant's medical and psychiatric records. The Supreme Court reversed the motion judge's order insofar as it denied the Commonwealth's motion for access to Defendant's medical and psychiatric records on behalf of the Rule 14(b)(2)(B) examiner, holding that the examiner's review of the treatment records was necessary to conduct a meaningful examination and to produce the requisite reports. View "Commonwealth v. Hanright" on Justia Law

This appeal was the last chapter in a case with a "long and tortuous procedural history." The sheriff of Suffolk County brought this appeal after Plaintiff, a jail officer employed by the sheriff, filed an action to enforce an arbitrator's award of back pay to Plaintiff after a finding that Plaintiff was wrongfully discharged. The sheriff appealed from the superior court ruling that Plaintiff had no duty to mitigate his damages by seeking comparable employment. The union for the jail officers and employees of the county, on behalf of Plaintiff, cross appealed from the judge's decision not to assess statutory postjudgment interest on the arbitrator's award. The Supreme Court affirmed, holding (1) Plaintiff had a duty to mitigate his damages, but the sheriff waived this issue by failing to raise it earlier in the proceedings; and (2) the superior court judge did not err in deciding not to assess postjudgment interest on sovereign immunity grounds. View "Sheriff of Suffolk County v. Jail Officers & Employees of Suffolk County" on Justia Law

Defendants were two passengers and a driver in a vehicle pulled over by a police officer for a traffic offense. The defendant passengers left the scene despite the officer's order for them to return to the automobile. The defendant driver was arrested for driving without a valid license. Subsequently two police officers searched the vehicle and found a firearm and drugs. Defendants were charged with various drug and firearm offenses. Defendants moved to suppress the evidence seized from the vehicle. The superior court allowed the motions, concluding that the warrantless search of the vehicle was not justified under any exception to the warrant requirement. The Supreme Court affirmed, holding (1) because the firearm was not in plain view, the search could not be justified as a search incident to arrest; and (2) because the defendant passengers did not abandon the contents of the vehicle when they left the scene, the search of the vehicle constituted an unlawful warrantless search. View "Commonwealth v. Perkins" on Justia Law

Defendant was a sex offender subject to the requirements of the Sex offender Registration and Community Notification Act. Following his release in prison, Defendant pleaded guilty to failing to register as a sex offender in violation of Mass. Gen. Laws ch. 6, 178H(a). The district judge imposed a fine and imposed community parole supervision for life (CPSL). Defendant moved to vacate the imposition of CPSL and to withdraw his pleas. The judge denied Defendant's motions. The Supreme Court affirmed, holding (1) chapter 6, section 178H(a) authorizes the imposition of CPSL where the sentence is a fine; (2) the amendment of the complaint to add Defendant's prior convictions serving as predicate offenses for the imposition of CPSL was proper; (3) Defendant received effective assistance of counsel in connection with the plea process; (4) the district court judge correctly found Defendant was criminally liable for failing to register; and (5) the district court judge did not abuse her discretion in denying Defendant's motion for a new trial on the basis of newly discovered evidence. View "Commonwealth v. Domino" on Justia Law

Employee filed suit against Employer, a limited liability company (LLC), and two of its managers under the Massachusetts Wage Act for failing to pay compensation that was allegedly owed to him under an employment contract. The superior court granted the managers' motion to dismiss, concluding that the Wage Act does not, by its plain language, impose individual liability on the managers of an LLC. The Supreme Court vacated the judgment of dismissal, holding that a manager who "controls, directs, and participates to a substantial degree in formulating and determining" the financial policy of the business entity may be a person having "employees in his service" under the Wage Act, and thus may be civilly or criminally liable for violations of the Act. Remanded. View "Cook v. Patient Edu, LLC" on Justia Law

After a jury trial, Defendant was convicted of involuntary manslaughter. At trial, Defendant contended that he stabbed the victim to death in self-defense. The evidence indicated that the victim was the first to provoke a nondeadly altercation with Defendant, but a dispute arose as to whether Defendant or the victim was the first to grab the knife that escalated the conflict into a deadly dispute. Defendant appealed, arguing that the trial judge erred by excluding evidence that the victim had participated in a violent assault of a third person less than two years after the incident resulting in the victim's death. The Supreme Court vacated the conviction, holding (1) a judge may admit "adjutant evidence" where there is a dispute as to who initiated a threat or use of deadly force; (2) the judge here erred in concluding that adjutant evidence was admissible only where there was a dispute as to who threatened or struck the first blow; and (3) this mistake resulted in prejudice to Defendant. Remanded for a new trial. View "Commonwealth v. Chambers" on Justia Law