Justia Massachusetts Supreme Court Opinion Summaries

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At issue in this case was the meaning and application of the stockholders’ agreement between Babcock Power Inc. and its former executive, Eric Balles. Babcock terminated Balles’ employment after discovering that he was engaged in an extramarital affair with a female subordinate. Concluding that Balles had been terminated “for cause” under the terms of his stockholders’ agreement with the company, the company’s board of directors “repurchased” Balles’ stock at a minimal price, withheld subsequent dividends, and refused to pay Balles any severance. Balles sought declaratory relief seeking that the stock be returned to him along with the withheld dividends. Balles prevailed at a jury-waived trial on his claim for declaratory relief but was unsuccessful in his request to receive severance pay. The Supreme Judicial Court affirmed, holding (1) the trial judge properly reviewed the board’s decision on a de novo basis; (2) the judge did not err in determining that Balles’ conduct did not constitute “cause” as defined in the stockholders’ agreement; and (3) Balles was not precluded from seeking relief pursuant to the terms of the stockholders’ agreement. View "Balles v. Babcock Power Inc." on Justia Law

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In these consolidated cases, shareholders of a publicly traded corporation (Plaintiffs) filed a complaint claiming that a merger transaction proposed by the board of directors would result in the effective sale of the corporation for an inadequate price. The superior court allowed Defendants’ motion to dismiss for failure to state a claim, concluding that the board owed no fiduciary duty directly to the shareholders and that the action was necessarily derivative. At issue on appeal was whether Plaintiffs must bring their claims against the members of the corporation’s board of directors as a derivative action on behalf of the corporation or may bring it directly on their own behalf. The Supreme Judicial Court affirmed, holding (1) the injury claimed by Plaintiffs, and the alleged wrong causing it, fit squarely within the framework of a derivative action; and (2) Plaintiffs’ claim was properly dismissed because they did not bring their claim as a derivative action. View "International Brotherhood of Electrical Workers Local No. 129 Benefit Fund v. Tucci" on Justia Law

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After a jury trial, Defendant was convicted of three counts of assault and battery and one count of kidnapping. The conviction arose out of an incident of domestic violence. The Supreme Judicial Court affirmed, holding (1) the trial judge did not abuse his broad discretion in finding an impermissible pattern at the point he rejected Defendant’s peremptory challenge to a certain female juror; (2) the trial judge did not err in admitting evidence of a prior incident of alleged domestic violence between Defendant and the victim; and (3) there was sufficient evidence to support Defendant’s kidnapping conviction. View "Commonwealth v. Oberle" on Justia Law
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After a jury trial, Defendant was convicted of murder in the second degree and carrying a firearm without a license. On appeal, Defendant argued, in part, that the trial judge erred in denying his motion for a mistrial on the ground that, during the jury’s deliberations, the jurors were exposed to extraneous materials and materials that had been excluded as evidence at trial. The Appeals Court rejected Defendant’s claims of error and affirmed the convictions. The Supreme Judicial Court affirmed, holding that the trial judge did not abuse her discretion in declining to declare a mistrial as a result of the jury’s exposure to the materials at issue during deliberations and in handling the circumstance as she did. View "Commonwealth v. Blanchard" on Justia Law
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After a jury trial, Defendant was found guilty of murder in the first degree on a theory of deliberate premeditation. Defendant appealed from his convictions and from the trial court’s denial of his motion for a new trial, arguing, inter alia, that the motion judge erred in denying his pretrial motion to suppress the testimony of a key prosecution witness because the Commonwealth had obtained his testimony as a result of an illegal wiretap that was previously ordered suppressed. The Supreme Judicial Court affirmed and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E, holding (1) the motion judge did not err in determining that the witness’s testimony was sufficiently attenuated from the suppressed wiretap evidence to dissipate the taint of illegality; and (2) trial counsel provided constitutionally effective assistance. View "Commonwealth v. Long" on Justia Law

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Defendants, Charles Mendez and Tacuma Massie, were convicted of murder in the first degree, armed robbery, and other offenses. Both defendants were charged on a theory of felony murder. Each defendant filed a timely notice of appeal. The Supreme Judicial Court affirmed Defendants’ convictions and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court did not err in denying Defendants’ motions to suppress evidence seized as a result of a warrantless stop that took place soon after the shooting; (2) the motion judge did not err in deciding to join for trial certain charges; (3) two aspects of the prosecutor’s closing argument challenged by Defendants were not error; (4) there was sufficient evidence to convict Massie of the armed robbery and felony murder; and (5) Defendants’ Moffett claims were unavailing. View "Commonwealth v. Mendez" on Justia Law

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Samuel S., a juvenile, was adjudicated a youthful offender and a delinquent juvenile as the result of a single sexual offense. As part of his sentence, Samuel was committed to the Department of Youth Services. The juvenile court judge also ordered Samuel to register as a sex offender and to submit to GPS monitoring, stating that both consequences were “mandatory.” The Supreme Judicial Court vacated the judge’s decision, holding (1) the pertinent section of the sex offender registration statute required the judge to make an individualized determination whether Samuel must register as a sex offender because he was not “sentenced to immediate confinement” within the meaning of the statute; and (2) the GPS monitoring statute, as interpreted by the Supreme Judicial Court in Commonwealth v. Hanson H., does not require youthful offenders to submit to GPS monitoring. View "Commonwealth v. Samuel S." on Justia Law
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After a jury-waived trial, Defendant was found guilty of breaking and entering in the daytime with the intent to commit a felony and larceny of property over $250. Defendant’s fingerprint at the crime scene constituted the only identification evidence. On appeal, Defendant argued that the evidence was insufficient to support the convictions. The Appeals Court affirmed. The Supreme Judicial Court reversed, holding that the evidence was not sufficient to find, beyond a reasonable doubt, that Defendant left his fingerprint at the time of the break-in, and therefore, there was insufficient evidence to support the convictions. View "Commonwealth v. French" on Justia Law
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This case concerned the arrival in Massachusetts of four minor siblings from a Nepalese refugee camp through a minor refugee program. The children’s parents subsequently arrived, but had very limited contact with the children after their arrival. The Department of Children and Families petitioned the probate and family court to free the children for adoption by terminating parental rights. The mother moved to deny the petition. The judge denied the motion and reported the matter to the appeals court, asking whether the Code of Federal Regulations allows the Department to petition for termination of parental rights under the circumstances of this case. The Supreme Judicial Court affirmed the judge’s denial of the mother’s motion to deny the Department’s petition, holding that the Code of Federal Regulations allows the Department to proceed to seek a termination of parental rights where unaccompanied refugee minors are present in the United States pursuant to the minor refugee program and the parents arrive in the United States but make no attempt to reunite with their children. View "In re Adoption of Yadira" on Justia Law
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This lawsuit arose from the explosion on the oil rig Deepwater Horizon that caused 4.9 million barrels of oil to flow into the Gulf of Mexico. Defendants, environmental activists, contributed an article appearing in an Internet Web site that contained criticism of Plaintiff, a scientific consulting firm retained to assess the toxic effects of the oil spill on cleanup workers. Plaintiff brought claims for defamation in Massachusetts and in New York. Defendants filed a special motion to dismiss the Massachusetts suit under the anti-SLAPP statute, Mass. Gen. Laws ch. 231, 59H. The superior court denied the motion, concluding that Defendants failed to meet their threshold burden of showing that the suit was based exclusively on the exercise of their right of petition under the Constitution. The Supreme Judicial Court reversed, holding (1) Defendants met their threshold burden because they were engaged in protected petitioning activity; and (2) Plaintiff could not show that such petitioning was devoid of reasonable factual support or arguable basis in law and therefore could not defeat the special motion. View "Cardno ChemRisk, LLC v. Foytlin" on Justia Law
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