Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of six counts of possessing child pornography. Each count was premised on one or two distinct photographs culled at the same time from a single cache on Defendant’s computer. Defendant appealed, arguing that his convictions were duplicative. The Supreme Judicial Court vacated the convictions and remanded for a new trial, holding (1) where offending photographs come from a single cache and the defendant is charged with possessing them at the same point in time, the proper unit of prosecution for the possession of child pornography is only a single unit of prosecution; and (2) accordingly, the entry of six separate convictions and sentences constituted multiple punishments for the same offense in violation of the guaranty against double jeopardy. View "Commonwealth v. Rollins" on Justia Law

Plaintiffs, twelve residential and business customers of Defendant Fitchburg Gas and Electric Light Company who lost power during a major ice storm, filed suit on behalf of themselves and those similarly situated, asserting claims of gross negligence and violation of Mass. Gen. Laws ch. 93A. Plaintiffs moved to certify a class, and the parties filed cross-motions for partial summary judgment on Plaintiffs’ chapter 93A claims. In their motion for partial summary judgment, Plaintiffs sought issue preclusive effect of findings made by the Department of Public Utilities (DPU) in two previous administrative adjudications related to Defendant’s conduct during the storm. The superior court judge (1) denied Plaintiffs’ motion for class certification; and (2) primarily denied the motions for summary judgment after applying offensive issue preclusion to factual findings made by the DPU. The Supreme Judicial Court affirmed, holding that the judge did not abuse his discretion in declining to certify a class and in applying issue preclusion to facts found after evidentiary hearings at the DPU. View "Bellermann v. Fitchburg Gas & Elec. Light Co." on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on theories of extreme atrocity or cruelty and felony-murder, based on the underlying felonies of home invasion and armed or assaultive burglary, and five related offenses. The jury did not specify whether they found Defendant guilty of the offenses as a principal or as a joint venturer. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to establish that Defendant shared the intent required to support his convictions; (2) there was no abuse of discretion in the manner in which the judge limited the scope of the cross-examination and the redirect examination of one of the Commonwealth’s witnesses; (3) the trial judge did not err in denying Defendant’s request for an instruction on murder in the second degree based on an uncharged offense or an instruction on intervening cause; and (4) counsel was not ineffective for failing to object when the judge instructed that accident was not a defense to the killing. View "Commonwealth v. Garcia" on Justia Law

The trustees of the Hollis W. Plimpton, Jr. Family Trust filed a complaint seeking a declaration that the trust as drafted correctly expressed the intent to the settlor that his estate be eligible to obtain the optimal benefit of allowable federal and state estate tax marital deductions. Alternatively, the trustees sought an order rewording a portion of the trust to ensure that it accomplished the settlor’s intent. The Supreme Judicial Court ordered that a judgment enter in the county court declaring that this was not a suitable occasion for the type of relief sought and dismissing the complaint, as the apparent objective of the parties - to insure by declaration or reformation that no person in the future misconstrues the document - is not something that justifies judicial involvement. View "Bank of Am., N.A. v. Babcock" on Justia Law

George C. Houser established the George C. Houser Trust, which established two trusts for the benefit of Mary R. Houser during her lifetime and gave her a power of appointment over one of the trusts (the marital trust). Upon Mary’s death in 1993, the principal remaining in the George C. Houser Trust was divided into two share trusts, one for each of the Housers’ sons. After George’s death in 1983, Mary established the Mary R. Houser Trust - 1991 and exercised her power of appointment over the marital trust property by appointing it to the trustees of the Mary Houser Trust. The trustees filed a complaint seeking reformation the trust established under Article Fourth of the Mary R. Houser Trust - 1991 to correct a drafting error that they contended frustrated the intent of Mary and George to provide for their descendants in an efficient and tax-advantageous manner. The Supreme Judicial Court ordered that the family trust be reformed by correcting the mistake in drafting, which inadvertently frustrated Mary’s estate planning objectives. View "Connell v. Houser" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. The Commonwealth’s theory at trial was that Defendant, who was in the midst of a contentious divorce from the victim, had engaged in a murder-for-hire scheme with Steven Stewart, who stabbed the victim, and their mutual friend, Richard Grebauski, the alleged middleman. The Supreme Judicial Court affirmed the conviction, holding (1) the trial court did not err in admitting a number of out-of-court statements introduced through Stewart’s testimony under the joint venture exception to the hearsay rule; (2) the trial court erred in admitting evidence that Defendant said he wanted his son killed and admitting testimony concerning a lumber theft by Stewart and Grebauski, but the errors did not result in a substantial likelihood of a miscarriage of justice; (3) the trial judge erred in deciding not to admit testimony concerning purportedly exculpatory statements made by Grebauski, but the error did not result in prejudice to Defendant; and (4) there was no prejudicial error in certain remarks made by the prosecutor during closing argument. View "Commonwealth v. Carriere" on Justia Law

Petitioners, Carolyn Faulk and Stanley Howard, commenced an action against Faulk’s former employer, CVS Caremark Corporation, and two of her former supervisors (collectively, Respondents), alleging that Respondents wrongfully terminated Faulk’s employment and discriminated against her on the basis of age and gender. The complaint further alleged that Howard had provided financial support to Faulk after her employment was terminated and that Howard sought damages from CVS on that basis. The trial court dismissed Howard’s claims for lack of standing and ultimately dismissed the entire complaint. Petitioners subsequently filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 challenging the trial court’s denial of Faulk’s request for counsel and the dismissal of Howard’s claims. A single justice of the Supreme Judicial Court denied the petition. The Supreme Judicial Court affirmed, holding (1) Petitioners’ claim regarding Faulk’s request for the appointed of counsel was moot; and (2) Howard had an adequate alternative remedy to challenge the dismissal of his claims by way of direct appeal. View "Faulk v. CVS Caremark Corp." on Justia Law

After the Town of Athol unilaterally increased copayment amounts that members of the Professional Firefighters of Athol, Local 1751, I.A.F.F. (Union) pay for medical services under their health insurance plans, the Union filed a grievance under the parties’ collective bargaining agreement (CBA). An arbitrator determined that the Town violated the CBA by making the changes unilaterally. The Town filed a complaint in the superior court seeking to vacate the award and other relief. The superior court confirmed the portion of the award compelling the parties to collectively bargain over changes to copayment rates and vacated two remedial aspects of the award. The Supreme Judicial Court reversed in part, holding that the superior court judge erred in vacating any portion of the award. Remanded for entry of a judgment confirming the award in its entirety. View "Town of Athol v. Prof’l Firefighters of Athol, Local 1751, I.A.F.F." on Justia Law

After a jury trial, Defendant was convicted of aggravated rape, kidnapping, and related crimes. In his third motion for a new trial, Defendant argued that his trial counsel was ineffective for failing to object to a court room closure during jury empanelment. The motion judge denied the motion without a hearing. Defendant sought reconsideration of the denial of his motion, arguing that prejudice under the second prong of the standard regarding ineffective assistance of counsel set forth in Commonwealth v. Saferian must be presumed due to the structural nature of the right to a public trial. The judge denied the motion. The Supreme Judicial Court affirmed, holding that where a defendant has procedurally waived a Sixth Amendment public trial claim by not raising it at trial and later raises the claim as one of ineffective assistance of counsel in a collateral attack on his conviction, the defendant is required to show prejudice from trial counsel’s deficient performance, and the presumption of prejudice that would otherwise apply to a preserved claim of structural error does not apply. View "Commonwealth v. LaChance" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on theories of extreme atrocity or cruelty and felony-murder, with armed robbery as the predicate felony. The Supreme Judicial Court affirmed the convictions, holding (1) the trial judge did not err in denying Defendant’s motions for a required finding of not guilty because the evidence was sufficient to establish that Defendant was at the scene of the crime during the period when the victim was robbed and killed; (2) the trial judge did not err in allowing the admission of expert testimony concerning the potential absence of blood on the victim’s killer; and (3) an error in the prosecutor’s closing argument did not create a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Evans" on Justia Law