Justia Massachusetts Supreme Court Opinion Summaries

Benjamin Tariri was charged with multiple counts of embezzlement and larceny, allegedly misappropriating nearly $2 million from clients while working as an attorney. He was arrested at Logan International Airport attempting to board a one-way flight to Iran, where he had recently spent six months. Tariri had longstanding ties to the United States but also significant connections to Iran. After his arraignment in the Boston Municipal Court, he was released on cash bail and required to submit to GPS monitoring with an inclusion zone restricting his movements to certain areas, primarily to mitigate his risk of flight.Following indictment and arraignment in the Superior Court, the bail and GPS conditions were maintained, with the inclusion zone expanded to cover additional areas. Tariri moved to modify or vacate the GPS condition, arguing that it hindered his ability to work and prevented him from visiting his wife and child in East Boston. The motion judge expanded the inclusion zone to address employment concerns but otherwise denied further relief. Tariri then filed a petition under G. L. c. 211, § 3, in the county court, which a single justice denied, finding no abuse of discretion or error of law in the trial court’s order.The Supreme Judicial Court of Massachusetts reviewed the single justice’s denial for clear error of law or abuse of discretion. The court held that GPS monitoring with an inclusion zone, imposed as a condition of pretrial release, was a reasonable and constitutional search under art. 14 of the Massachusetts Declaration of Rights, given the particularized risk of flight and the legitimate governmental interest in ensuring Tariri’s appearance in court. The judgment of the single justice was affirmed. View "Tariri v. Commonwealth" on Justia Law

A man was convicted by a jury of first-degree murder, aggravated assault and battery by means of a dangerous weapon, and armed assault with intent to murder, following a shooting outside a residence in Boston. Surveillance footage and cell phone records linked him to the scene, and police later recovered clothing matching that worn by the shooter from an apartment where he was staying. The defendant was arrested about a week after the incident. The police obtained a search warrant for the apartment, and the search yielded evidence used at trial.In the Superior Court, the defendant moved to suppress evidence from the apartment, arguing that the search warrant was tainted by a statement he made to police that was later suppressed, and that the warrant affidavit omitted material information. The judge denied both the motion to suppress and the request for a Franks hearing. During jury selection, the judge allowed the Commonwealth to exercise a peremptory strike against a Black juror after finding the prosecutor’s reason was race-neutral and genuine, and excused another juror for cause based on her views about police credibility, which the defendant challenged. The judge also excused two jurors who could not serve due to a religious holiday. At trial, the judge permitted a police officer familiar with the defendant to identify him in surveillance footage, and denied a motion for mistrial after a dispute over the officer’s testimony about prior encounters with the defendant.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the search warrant was valid under the independent source doctrine and that the affidavit established probable cause without the suppressed statement. The Court found no abuse of discretion in the jury selection rulings or in admitting the identification testimony. The Court affirmed the convictions for murder, aggravated assault and battery, and armed assault with intent to murder, but vacated the conviction for unlawful possession of a firearm and remanded for further proceedings on that charge. View "Commonwealth v. Almeida" on Justia Law

The plaintiff was employed as a senior director of finance at a data management software company, which later rebranded following a merger. Initially hired full time, the plaintiff’s position was later reduced to part time with a corresponding salary adjustment. Around this time, the plaintiff and the company entered into a retention bonus agreement, which provided for two bonus payments if the plaintiff remained employed and in good performance standing, with no reduction in work schedule, through two specified dates. The agreement also required the plaintiff to return the bonus if he left voluntarily or was terminated for cause before those dates. The plaintiff remained employed through both retention dates and received both bonus payments, though the second payment was made eight days after his termination due to a reduction in force.The plaintiff filed suit in the Concord Division of the District Court Department, asserting, among other claims, that the company violated the Massachusetts Wage Act by failing to pay the second retention bonus on his last day of employment. Both parties moved for summary judgment, which were denied without explanation. Upon reconsideration, a different District Court judge entered judgment for the defendants, finding that the retention bonus was not a “wage” under the Wage Act because it was contingent compensation. The Appellate Division of the District Court Department affirmed this decision, and the plaintiff sought further review.The Supreme Judicial Court of Massachusetts granted direct appellate review. It held that retention bonus payments conditioned on continued employment and other requirements are not “wages” under the Wage Act, but rather constitute additional, contingent compensation. The court affirmed the judgment in favor of the defendants, concluding that the Wage Act did not apply to the retention bonus payments at issue. View "Nunez v. Syncsort Incorporated" on Justia Law

The defendant was charged with first-degree murder after fatally shooting Trung Tran, an innocent bystander, during an altercation with Irving Sanchez at a salon. The defendant claimed that Sanchez initiated the confrontation, displayed a firearm, and threatened him, prompting the defendant to fire two shots in self-defense. One of these shots struck Tran, who was nearby. Witnesses provided differing accounts, with some stating that Sanchez struck the defendant and that the defendant fired in response, but none confirmed that Sanchez was armed. The defendant admitted to the shooting and was arrested at the scene.A Hampden County grand jury indicted the defendant for murder. The Superior Court, recognizing the novel legal issue of transferred intent self-defense, reported questions of law to the Appeals Court regarding whether this defense is available in Massachusetts and, if so, whether it is a complete or partial defense. The Supreme Judicial Court of Massachusetts granted direct appellate review to address these questions.The Supreme Judicial Court held that a defendant may assert transferred intent self-defense to justify the killing of an unintended victim, such as an innocent bystander, if the killing occurred during the lawful exercise of self-defense against an assailant. However, this defense is only partial: if the defendant’s conduct in exercising self-defense was wanton or reckless, resulting in a high likelihood of substantial harm to an unintended victim, the defendant may be held criminally liable for involuntary manslaughter, not murder. The court remanded the matter to the Superior Court for further proceedings consistent with this opinion. View "Commonwealth v. Santana-Rodriguez" on Justia Law

A staff member at a university medical school morgue, Cedric Lodge, engaged in a scheme over several years in which he dissected, stole, and sold body parts from cadavers that had been donated for research and education. After Lodge’s federal indictment became public, forty-seven relatives of individuals whose remains were potentially mishandled sued the university, the managing director of the anatomical gift program (Cicchetti), and the program manager (Fay). The plaintiffs alleged that the university and its staff failed to ensure the dignified treatment and disposition of donated remains, pointing to inadequate security and oversight, and referenced a similar prior scandal at another institution.The cases were consolidated in the Massachusetts Superior Court, where the defendants moved to dismiss all claims, arguing they were protected by the “good faith” immunity provision of the Uniform Anatomical Gift Act (UAGA). The Superior Court judge granted the motion, finding that the complaints did not plausibly suggest the defendants failed to act in good faith or were legally responsible for Lodge’s actions.The Supreme Judicial Court of Massachusetts reviewed the case after transferring it from the Appeals Court. The court held that the UAGA’s good faith immunity applies to the entire anatomical donation process, including the final disposition of remains. The court further held that the plaintiffs’ allegations against the university and Cicchetti, if true, could support a finding of “peculiarly pervasive noncompliance” with the act, sufficient to infer a lack of good faith and defeat the motion to dismiss at this stage. However, the court found the allegations against Fay insufficient to overcome the good faith defense. The court reversed the dismissal as to the university and Cicchetti (except for respondeat superior claims), affirmed dismissal as to Fay, and remanded for further proceedings. View "Weiss v. President and Fellows of Harvard College" on Justia Law

The defendant was charged with twenty-one felony counts stemming from a fifteen-minute crime spree in February 2019, during which he attempted to break into homes, engaged in a physical altercation, stopped vehicles at gunpoint, and was ultimately apprehended by police. He was arraigned in May 2019 and held on high bail. Over the next several years, the case was delayed by issues including the Commonwealth’s slow production of mandatory discovery, changes in defense counsel, and the defendant’s own motions and requests. The COVID-19 pandemic led to statewide orders suspending jury trials for extended periods, further delaying proceedings.The case was heard in the Hampden Superior Court, where the defendant filed multiple motions to dismiss, arguing that the delay violated both the Massachusetts Rules of Criminal Procedure (rule 36) and his constitutional right to a speedy trial. The Superior Court judge excluded various periods from the speedy trial calculation, including time attributable to COVID-19 orders, delays caused by defense motions, and periods when the defendant changed counsel or requested continuances. The defendant was ultimately convicted on most counts after a bench trial, and he appealed directly to the Supreme Judicial Court.The Supreme Judicial Court of Massachusetts held that delays resulting from its COVID-19 orders do not weigh against the Commonwealth in evaluating constitutional speedy trial claims. The Court further found that, after excluding periods attributable to the pandemic, defense motions, and other justified delays, the remaining delay did not violate rule 36 or the defendant’s constitutional rights under the Sixth Amendment or Article 11 of the Massachusetts Declaration of Rights. The Court affirmed the defendant’s convictions. View "Commonwealth v. Larace" on Justia Law

A member of the Lowell police department’s gang unit created an undercover Snapchat account using a “nonwhite” username and bitmoji, aiming to monitor gang activity by befriending users connected to other officers’ undercover accounts. The officer became “friends” with a user believed to be the defendant, though he did not know the user’s identity or race at the time. The defendant posted a video of himself discharging a firearm from a car, which led police to identify and locate him. A search of the defendant’s vehicle uncovered a firearm matching the one in the video and shell casings consistent with those found at the scene. The defendant did not possess a license to carry a firearm.The Lowell Division of the District Court Department charged the defendant with multiple firearms offenses. The defendant sought discovery on a selective enforcement claim, and the court ordered the production of relevant police records and policies. The records showed that all suspects charged from Snapchat investigations with identifiable race were nonwhite. The defendant moved to suppress evidence, arguing racial motivation in the investigation, but a District Court judge denied the motion, finding no reasonable inference of racial motivation. The defendant also moved to dismiss the firearms charges, claiming the resident firearm licensing scheme violated the Second Amendment. Another District Court judge denied this motion, finding the problematic provision severable. The defendant entered conditional guilty pleas, reserving his right to appeal.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the defendant had raised a reasonable inference of selective enforcement under the Commonwealth v. Long framework and remanded for an evidentiary hearing, requiring the Commonwealth to rebut the inference with a race-neutral reason. The court also held that the Commonwealth’s resident firearm licensing scheme was not facially unconstitutional under the Second Amendment, affirming the denial of the motion to dismiss. View "Commonwealth v. Rodriguez" on Justia Law

The case involved a defendant who was convicted by a jury in 2020 of murder in the first degree, armed robbery, larceny of a motor vehicle, and unlawful possession of a firearm. The events leading to the charges began when the defendant, his girlfriend, and the victim lived together in Florida, using proceeds from a house sale to fund hotel stays and drug purchases. After a falling out, the defendant and the victim traveled to Massachusetts, where tensions escalated over money. The defendant ultimately shot the victim in a Massachusetts park after a series of text messages and conversations indicating premeditation. The defendant admitted to the killing but claimed self-defense and mental impairment due to longstanding mental illness and substance use.The Superior Court conducted a twelve-day trial, after which the jury found the defendant guilty on all counts. The defendant was sentenced to life without parole for murder, with additional consecutive sentences for the other convictions. He appealed his convictions and filed a motion for a new trial, arguing ineffective assistance of counsel and prosecutorial misconduct. The trial judge, who also heard the motion for a new trial, denied the motion after evidentiary hearings, finding that counsel’s investigation into the defendant’s mental health history was sufficient and that the strategic decision not to introduce corroborating medical records was reasonable.The Supreme Judicial Court of Massachusetts reviewed the consolidated appeals. The court held that the trial judge did not abuse his discretion in denying the motion for a new trial. It found no substantial likelihood of a miscarriage of justice from counsel’s investigation or strategic decisions, and determined that the prosecutor’s conduct did not improperly shift the burden of proof or prejudice the defendant. The court affirmed the convictions for murder, armed robbery, and larceny, and the denial of the new trial motion. However, it vacated the firearm conviction due to insufficient evidence regarding licensure and remanded for further proceedings on that count. View "Commonwealth v. Noguera" on Justia Law

In this case, the defendant, a lawyer, was accused of delivering sixty-one orange strips containing Suboxone, a controlled substance, to an inmate at a county house of correction. The delivery was disguised as legal paperwork following instructions from another inmate. The strips were confiscated by officers who suspected they were Suboxone. Forensic testing was performed by analyst Dunlap, who concluded the strips contained Suboxone. Dunlap documented her procedures and results in her notes, but was no longer employed at the crime lab at the time of trial. Instead, LaBelle, a supervisor who had not participated in or observed the testing, reviewed Dunlap’s work and testified as a substitute expert, relaying Dunlap’s notes and offering her own opinion based on the case file.A jury in the Massachusetts Superior Court found the defendant guilty of unlawfully delivering a class B controlled substance to a prisoner. The Appeals Court affirmed the conviction, reasoning that LaBelle’s opinion was independent. After the United States Supreme Court decided Smith v. Arizona, the Supreme Court granted certiorari, vacated the Appeals Court’s judgment, and remanded for reconsideration in light of Smith. The Supreme Judicial Court of Massachusetts then transferred the case for review.The Supreme Judicial Court of Massachusetts held that the admission of LaBelle’s testimony violated the defendant’s Sixth Amendment right to confront witnesses. The Court found that LaBelle’s opinion was not independent, as it depended on the truth of Dunlap’s testimonial hearsay statements regarding the procedures and results of the testing. The Court concluded that this error was not harmless beyond a reasonable doubt and vacated the conviction, remanding for a new trial. The Court also held that its new rule applies prospectively to cases not yet final. View "Commonwealth v. Gordon" on Justia Law

An individual pleaded guilty to multiple sexual offenses committed against two girls, aged thirteen and fourteen, when he was eighteen years old. The offenses included several instances of rape and indecent assault. The individual had a history of psychological diagnoses, including autism spectrum disorder. After his conviction, the Sex Offender Registry Board (SORB) initially classified him as a level three sex offender, which would require the highest level of public notification. The individual challenged this classification, leading to a de novo hearing before a SORB hearing examiner.At the hearing, the examiner found by clear and convincing evidence that the individual posed a moderate risk of reoffense and a moderate degree of danger, resulting in a reclassification to level two. The examiner considered several statutory and regulatory factors, including the number of victims, the nature and location of the offenses, and the individual’s psychological profile. The examiner also considered the fact that the individual committed multiple offenses, including repeated offenses against one victim, as relevant to the degree of dangerousness. The examiner determined that Internet publication of the individual’s registration information would serve a public safety interest. The individual sought judicial review in the Massachusetts Superior Court, which affirmed the SORB’s decision.The Supreme Judicial Court of Massachusetts reviewed the case after transferring it from the Appeals Court. The court held that the SORB hearing examiner did not err in considering the individual’s multiple offenses as relevant to dangerousness under regulatory factor thirty-seven, even though such consideration is limited under factor two, which addresses risk of reoffense. The court also declined to find the application of factor thirty-seven unconstitutional due to a lack of empirical evidence, given the statutory mandate to consider the number of offenses. The court affirmed the classification as a level two offender and the requirement for Internet dissemination of registration information. View "Doe v. Sex Offender Registry Board" on Justia Law