Justia Massachusetts Supreme Court Opinion Summaries

James Walsh, an electrician, became a member of the Massachusetts Teachers' Retirement System (MTRS) when he began teaching at a vocational school. Before the effective date of his retirement in 2006, Defendant applied to MTRS to increase his anticipated retirement allowance by adding to his creditable service through the buyback of three years of creditable service based on his work experience as an electrician. MTRS assessed buyback interest to commence as of 1977, the beginning of the three-year period for which Walsh sought trade service credit. Walsh appealed, claiming that buyback interest should not have begun to accrue until 1987, when he became a member of the MTRS. The Contributory Retirement Appeal Board (CRAB) reversed, holding (1) the regulation promulgated by MTRS was a valid exercise of MTRS's statutory authority; and (2) CRAB's failure to assess interest in accordance with 807 Mass. Code Regs. 14.05 was an error of law. View "Mass. Teachers' Ret. Sys. v. Contributory Ret. Appeal Bd." on Justia Law

A grand jury returned twenty-two indictments against Defendant, including indictments charging murder in the first degree and various counts of masked armed robbery. The charges arose out of a robbery of a department store perpetrated by Domenic Cinelli. The Commonwealth proceeded against Defendant as a joint venturer and coconspirator. Defendant filed a motion to dismiss (1) indictments relating to Cinelli's escape-related offenses as not supported by sufficient evidence, and (2) the portion of the murder indictment that included any theory of murder other than felony-murder. The motion judge dismissed the challenged indictments and the portion of the murder indictment that included theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Court (1) reversed the grant of Defendant's motion to dismiss the indictments that charged Defendant with the assault and battery and firearm crimes perpetrated by Cinelli during his escape, holding (i) Defendant may be liable for Cinelli's escape-related crimes where the Commonwealth proves that he participated in, and intended, such crimes; and (2) reversed the grant of Defendant's motion to dismiss the prevented the Commonwealth from proceeding at trial on all three theories of murder, holding that sufficient evidence supported the indictment. View "Commonwealth v. Hanright" on Justia Law

In 2011, Defendant was indicted for distributing cocaine and for being a second or subsequent offender in violation of section Mass. Gen. Laws ch. 94C, 32A(d). In 2012, before Defendant's trial had commenced, the Legislature enacted the Crime Bill, which amended the enhanced penalty provision of section 32A(d) by reducing the mandatory minimum sentence. Twenty days later, Defendant was found guilty. The judge imposed a mandatory minimum prison sentence as permitted by the Crime Bill. The Commonwealth requested that the judge correct the sentence so as to comply with the sentencing provisions as they existed on the date Defendant committed the offense. The judge denied the request, concluding that the Crime Bill made the sentencing reductions applicable to persons sentenced after the effective date of the new act even if the offense was committed before the effective date of the act. The Supreme Court denied the Commonwealth's petition for relief, holding that to interpret the statute amending the mandatory minimum sentence in section 32A(d) not to apply to Defendant would be inconsistent with the manifest intent of the Legislature. View "Commonwealth v. Galvin" on Justia Law

Karl McGhee, a financial advisor at LPL Financial, acted as financial planner for Plaintiff. Plaintiff filed a complaint against McGhee and LPL, asserting claims for, inter alia, violations of Mass. Gen. Laws ch. 93A. Defendants moved for an order compelling the parties to proceed to arbitration due to an arbitration agreement signed by Plaintiff. The motion judge denied the motion, concluding that none of Plaintiff's claims could be compelled to arbitration because claimants under chapter 93A, section 9 are not required to submit to arbitration. The Supreme Court reversed, holding (1) claims alleging an unfair or deceptive trade practice in violation of chapter 93A, section 9 must be referred to arbitration where the contract involves interstate commerce and the agreement is enforceable under the Federal Arbitration Act (FAA); and (2) because Plaintiff and Defendants in this case entered into a valid contract whereby they agreed to settle all controversies related to Plaintiff's financial account by arbitration, and because the arbitration agreement was governed by the FAA, Defendants as a matter of law were entitled under the FAA to a stay of judicial proceedings and an order compelling arbitration. Remanded. View "McInnes v. LPL Fin., LLC" on Justia Law

Plaintiff filed suit against Defendants for failing to pay compensation he alleged was owed to him under an employment contract. The complaint asserted claims for, inter alia, breach of contract and violations of the Wage Act. The superior court dismissed all but Plaintiff's claim under the Wage Act, concluding that the Wage Act was the exclusive remedy for the recovery of unpaid claims, thereby preempting Plaintiff's common-law claims. The Supreme Court reversed, holding that the legislature did not intend the Wage Act to be the exclusive remedy for the recovery of unpaid wages, and therefore, Plaintiff's common-law claims should not have been dismissed. Remanded. View "Lipsitt v. Plaud" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress statements he made to police, as (i) Defendant knowingly, intelligently, and voluntarily waived his Miranda rights, (ii) Defendant's statements were voluntarily made, and (iii) Defendant was not intentionally deprived of his statutory right to make a telephone call until he was booked; and (2) the judge slightly erred in instructing the jury on murder in the first degree committed with extreme atrocity or cruelty, but the error did not prejudice Defendant. View "Commonwealth v. Walker" on Justia Law

After a jury trial, Defendant was convicted of four charges of possession of firearms and ammunition. At issue on appeal was which two of four convictions must be vacated because they were duplicative. Defendant argued that the two convictions on lesser included offenses should be vacated even though they carried higher penalties, and the Commonwealth argued that the convictions carrying lesser penalties should be vacated. The Supreme Court (1) vacated two of the convictions and sentences as duplicative and remanded for a judge to decide which conviction in each set of paired convictions should be vacated; and (2) affirmed Defendant's motions to suppress and for a mistrial, holding (i) the vehicle stop during which the firearm was seized was lawful, and (ii) testimony given at trial indicating that the police were conducting narcotics surveillance when an officer observed Defendant with a gun was not prejudicial. View "Commonwealth v. Rivas" on Justia Law

Defendants Cory Moody and David Newman were separately indicted for violations of the Controlled Substances Act arising from their alleged involvement in an organized group engaged in drug trafficking. Prior to trial, Defendants filed motions to suppress the fruits of several search warrants issued under the Massachusetts wiretap statute authorizing the interception of calls and text messages sent over their cell phones. Defendants argued that the interceptions were beyond the scope of authority provided under the state wiretap statute and thus were preempted by the federal wiretap statute. The motion judge denied Defendants' motions as to their cell phone calls but granted the motions as to the interception of Defendants' text messages. The judge then reported a question to the appeals court, and the Supreme Court answered by holding that a superior court judge possesses the authority under the Massachusetts wiretap statute to issue warrants permitting the interception of cell phone calls and text messages. Remanded. View "Commonwealth v. Moody" on Justia Law

The City of Boston transferred a Boston police sergeant who served as a union representative due to what the City said were ongoing concerns about the officer's supervisory authority. The Boston Police Superior Officers Federation (union) sought to enforce a provision of its collective bargaining agreement (CBA) with the City, which prohibited the involuntary transfer of certain union representatives between stations or assignments. A grievance arbitrator concluded that the City had violated the CBA and awarded the officer damages and reinstatement to his original position. The superior court confirmed the award. The Supreme Court vacated the superior court's judgment and remanded the case for judgment vacating the award, holding that the arbitrator exceeded his authority in invalidating the officer's transfer, where assignment and transfer of officers within the Boston police department are nondelegable statutory powers of the Boston police commissioner. View "City of Boston v. Boston Police Superior Officers Fed'n" on Justia Law

Insureds purchased a homeowner's insurance policy from Insurer with a personal liability limit of $500,000. The policy contained an animal liability endorsement (endorsement) which limited coverage to $25,000 for claims arising from animal bites. Both Insurer's agent and Insureds mistakenly believed the policy did not contain the limitation of liability but neither conveyed their mistaken belief to the other. After Plaintiff was bitten by Insured's dog, he and his wife successfully brought an action against Insureds. Insurer paid only $25,000 of this judgment. Plaintiffs and Insureds reached a settlement regarding the balance of the judgment and Plaintiffs became assignees of Insureds' claims against Insurer. Plaintiffs sued Insurer, alleging that Insureds and Insurer were mutually mistaken as to the application of the endorsement, and therefore, the policy should be reformed by striking the endorsement. The superior court concluded Plaintiffs were entitled to summary judgment on the reformation claim. The Supreme Court vacated the judgment, holding that, absent full, clear, and decisive proof of some prior agreement between the parties as to coverage for animal bites different than that contained in the policy, there was no mutual mistake warranting reformation of the policy. View "Caron v. Horace Mann Ins. Co." on Justia Law