Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in January, 2014
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After a jury trial, Defendant was convicted of murder and related firearm charges. The appeals court affirmed. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to the police during an interview at the police station. The Supreme Court affirmed, holding that the trial court did not err in admitting the statements where (1) because Defendant’s claimed invocations of the right to counsel were made before the interrogation became custodial, Defendant did not effectively invoke that right; (2) the totality of the circumstances supported the conclusion that Defendant’s statements were voluntary; and (3) even if Defendant did not validly waive his Miranda rights before making statements during the custodial portion of the interview, the admission of those statements was harmless beyond a reasonable doubt. View "Commonwealth v. Molina" on Justia Law

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Plaintiff applied for harassment prevention orders against Defendant because, apparently, several months after Defendant moved out of the apartment he and Plaintiff shared, Defendant drove past Plaintiff as she stood outside the front of her home and then drove past Plaintiff again two more times. The lower court judge found enough evidence to extend the orders. The appeals court dismissed Defendant’s appeal as moot because the harassment prevention order had expired. The Supreme Court remanded the case, holding (1) pursuant to Seney v. Morhy, Defendant’s appeal should not have been dismissed as moot; and (2) there was insufficient evidence to support the issuance of the harassment prevention orders. View "Smith v. Mastalerz" on Justia Law

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Plaintiff was an assistant coach of a little league baseball team for which Defendant’s son played. Plaintiff applied for a harassment prevention order against Defendant, stating that he was fearful for himself and his family. A district court judge issued a harassment prevention order against Defendant. Defendant filed her appeal on May 19, 2011. The harassment prevention order expired on April 20, 2012. On November 13, 2012, the appeals court dismissed Appellant’s appeal as moot because the harassment prevention order had expired. The Supreme Court remanded for entry of an order vacating the harassment prevention order against Defendant, holding (1) appeals from expired harassment prevention orders should not be dismissed as moot where the parties have a continuing interest in the case, and Defendant in this case still had a stake in the outcome of the appeal, including removing any stigma from her name through the destruction of the order; and (2) there was insufficient evidence to issue the harassment prevention order against Defendant. View "Seney v. Morhy" on Justia Law

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After a jury trial, Defendant, who was a juvenile at the time of the offense for which he was found guilty, was convicted of murder in the first degree for his knowing participation along with three other young men in the killing of the victim. The Supreme Court (1) affirmed Defendant’s conviction, holding (i) Defendant’s trial counsel did not render constitutionally deficient assistance by failing to obtain a full transcript of a witness’s testimony from another trial for impeachment purposes, (ii) the admission of state of mind evidence did not prejudice Defendant under the circumstances, and (iii) the prosecutor’s inconsistent closing argument at another trial related to the killing and Defendant’s trial did not prejudice Defendant; and (2) vacated Defendant’s sentence and remanded for resentencing, holding that Defendant’s sentence of life in prison without parole was invalid under the Eighth Amendment. View "Commonwealth v. Keo" on Justia Law

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Plaintiff was the owner of a parcel of land that was subject to and had the benefit of several easements, including Way A, which was created so the easement holder could access his lot, which otherwise had no direct access from a public way. Defendant held title to three lots over which Way A extended and made improvements that protruded to some extent into Way A. Plaintiff filed a complaint asserting acts of encroachment upon its right to use the easement over Way A. The Land Court judge found that Defendant had no obligation to remove any of the encroachments. The Appeals Court reversed in part, concluding that because Plaintiff’s parcel was held under a Land Court certificate of registration, the dimensions of all easements appurtenant to it indicated on the Land Court plan were immutable, and therefore, Plaintiff had had right of access over the full width of Way A as shown on the plan. The Supreme Court affirmed the decision of the Land Court judge, holding that the width of the easement may be reduced since Plaintiff did not dispute that he had been able to use the remaining unobstructed portion of the easement for the purpose of travel to and from his parcel. View "Martin v. Simmons Props., LLC" on Justia Law

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Defendant was convicted of two indictments alleging receipt of stolen property. Defendant appealed, arguing that the judge erred in denying his motion to suppress because the arrest warrants leading to the search of an apartment where the stolen property was discovered did not authorize the police to enter the apartment. Specifically, Defendant argued that the police did not have a “reasonable belief” that Defendant was present in the apartment, and therefore, the subsequent seizure of the stolen property was the fruit of this unconstitutional entry. The Supreme Court vacated the convictions and remanded, holding (1) a “reasonable belief” requires more than was known at the time of entry in this case; and (2) therefore, the entry was unconstitutional, and the observation and subsequent seizure of the stolen property allegedly received by Defendant should have been suppressed as the fruit of the illegal entry. View "Commonwealth v. Gentile" on Justia Law

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When Rita Licata was transferred to a nursing facility operated by Defendant Rita’s son Salvatore signed an agreement with the facility to arbitrate disputes arising from Rita’s stay at the facility. Salvatore signed the agreement in the space provided for the resident’s “authorized representative.” Rita suffered personal injuries at the nursing facility resulting in her death. Salvator filed a complaint as administrator of Rita’s estate against Defendant for, inter alia, wrongful death and negligence. Defendant filed a motion to dismiss the complaint and to compel arbitration. The motion judge denied the motion, concluding that Salvatore lacked authority to execute the arbitration agreement on Rita’s behalf. The Supreme Court affirmed, holding (1) Salvatore lacked authority to execute the agreement on Rita’s behalf; and (2) the arbitration agreement did not otherwise bind Rita’s estate. View "Licata v. GGNSC Malden Dexter LLC" on Justia Law

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Barbara Johnson, in her capacity as her husband Dalton’s health care agent, signed an agreement with a nursing facility to arbitrate disputes arising from Dalton’s stay at the facility. While a resident of the facility, Dalton suffered burns and later died. The administrators of Dalton’s estate, filed a complaint against nursing home defendants and others, arguing that Barbara, as Dalton’s health care agent, did not have the authority to execute the arbitration agreement on his behalf. A superior court judge entered an order compelling mediation or arbitration. The Supreme Court vacated the order of the superior court, holding that a health care agent’s decision to enter into an arbitration agreement is not a health care decision under the health care proxy statute, and therefore, an agreement to arbitrate all claims arising out of a principal’s stay in a nursing facility does not bind the principal where the agreement was entered into solely by a health care agent under the authority of a health care proxy. View "Johnson v. Kindred Healthcare, Inc." on Justia Law

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Defendant was incarcerated for rape of a child when the Commonwealth filed a petition to have him declared a sexually dangerous person (SDP). Several months after the conclusion of a jury-waived trial, a superior court judge issued a decision concluding that Defendant was an SDP and ordering him committed to a treatment center. Defendant appealed, arguing, among other things, that the trial judge erred in failing to issue a decision within thirty days of the end of trial in accordance with Commonwealth v. Blake. The court of appeals affirmed. The Supreme Court affirmed, holding that although the trial judge’s decision was not issued within thirty days as required by Blake, neither dismissal of the Commonwealth’s petition nor a new trial was warranted under the circumstances. View "Commonwealth v. Pariseau" on Justia Law

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After a second jury trial, Defendant was convicted of rape of a child. Prior to trial, Defendant moved to compel the production of psychological records of the complainant in the custody of the complainant’s psychologist. The motion judge denied the motion, concluding that statements by the complainant to her psychologist concerning the alleged assault, without more, did not meet the threshold requirements of Commonwealth v. Dwyer and Commonwealth v. Lampron. The court of appeals affirmed. The Supreme Court remanded the case to the superior court, holding that a summons for the production of the psychologist’s records related to the complainant’s sexual assault should have issued in this case. Remanded. View "Commonwealth v. Labroad" on Justia Law