Justia Massachusetts Supreme Court Opinion Summaries

In 2023, Kenneth Bresler, a former Appeals Court staff attorney, filed a lawsuit in the Superior Court against three Appeals Court employees, Lynn Muster, Mary Bowe, and Gina DeRossi, alleging intentional interference with advantageous relations. Bresler claimed that the defendants engaged in a campaign that led to his termination. The defendants moved to dismiss the complaint, arguing that Bresler failed to establish the "actual malice" required for such a claim and that they were entitled to common-law immunity as public officials.The Superior Court judge granted the motion to dismiss for Bowe and DeRossi but denied it for Muster. Bresler appealed the dismissal of Bowe and DeRossi, while Muster cross-appealed the partial denial of her motion to dismiss. The Supreme Judicial Court granted Bresler's application for direct appellate review.The Supreme Judicial Court reviewed the case and concluded that the allegations in the complaint, when taken as true, plausibly suggested that Muster and Bowe acted with "actual malice," which is necessary to state an intentional interference claim. The court found that Muster's actions, motivated by jealousy and hostility, and Bowe's subsequent negative evaluations and actions against Bresler, supported the inference of actual malice. However, the court held that the complaint did not contain sufficient factual allegations to establish actual malice or defeat common-law immunity for DeRossi.As a result, the Supreme Judicial Court affirmed the Superior Court's order as to Muster and DeRossi and reversed it as to Bowe, allowing the claims against Muster and Bowe to proceed while dismissing the claims against DeRossi. View "Bresler v. Muster" on Justia Law

The case involves a dispute between two parents, Bharathan Jeevanandam and Vanikala Bharathan, regarding child support payments. The parents divorced in 2012, and the father was ordered to pay child support to the mother, who had primary physical custody of their child. In 2021, the father filed a complaint for modification, seeking to terminate his child support obligation because the child was enrolled in a full-time residential program paid for by the municipalities. The Probate and Family Court terminated the father's child support obligation retroactively to January 1, 2022.The father then sought reimbursement from the mother for the child support payments made after the retroactive termination date. The Probate and Family Court ordered the mother to repay the father at a rate of $80 per week through the Department of Revenue Child Support Enforcement Division. The department, however, contended that it lacked the authority to enforce the reimbursement order because it was not an order for child support. The judge denied the department's motion for reconsideration, leading to the department's appeal.The Supreme Judicial Court of Massachusetts reviewed the case and determined that the Department of Revenue does not have the authority to enforce a judgment requiring one parent to reimburse the other for overpayment of child support when the reimbursement does not go to support the child. The court held that the department's enforcement authority is confined to judgments, decrees, and orders that are "for the support and maintenance of a child" as defined by G. L. c. 119A, § 1A. Since the reimbursement in this case did not go to support or maintain the child, the court vacated the portion of the second amended judgment that required the department to enforce the reimbursement obligation through wage assignment. View "Jeevanandam v. Bharathan" on Justia Law

The defendant was charged with operating a motor vehicle while under the influence of alcohol (OUI), third offense, resisting arrest, and three civil motor vehicle violations. After being stopped by police, the defendant exhibited signs of intoxication and was arrested. At the police station, he refused a breath test and was taken to a hospital where blood tests were conducted as part of his medical treatment. The police obtained a search warrant for the defendant's blood samples and sent them to the State police crime laboratory for analysis. The defendant moved to suppress the blood sample evidence, arguing he did not consent to the blood test.The motion to suppress was allowed by the lower court, which ruled that the blood sample and any analysis conducted by the State police were inadmissible. The Commonwealth obtained the defendant's medical records, which included the blood test results, and a forensic scientist converted these results to a blood alcohol content (BAC) percentage. The defendant moved to exclude this converted BAC evidence, and the trial judge agreed, reasoning that it was derived from suppressed evidence. The Commonwealth's motion for reconsideration was denied, and they petitioned for extraordinary relief.The Supreme Judicial Court of Massachusetts reviewed the case and held that the consent provision of General Laws c. 90, § 24 (1) (e), which requires a defendant's consent for the admissibility of blood or breath test results conducted by or at the direction of police, does not apply to the mathematical conversion of serum/plasma ethanol results from medical records to a BAC percentage. The court concluded that this conversion is not a "chemical analysis" as defined by the statute. Therefore, the converted BAC evidence is admissible, and the lower court's decision to exclude it was reversed. The case was remanded for further proceedings consistent with this opinion. View "Commonwealth v. Gannett" on Justia Law

Sergeant John Babcock, a member of the Newton police department, was transferred from his position as a traffic sergeant with regular daytime hours to a night shift sergeant position. This transfer occurred after Babcock had been actively involved in union activities, including disputes with the police chief, David MacDonald. Despite receiving an eight percent pay increase as stipulated in the collective bargaining agreement (CBA), Babcock's new position required him to work irregular nighttime hours, weekends, and holidays, which he claimed negatively impacted his family life.The Commonwealth Employment Relations Board (CERB) reviewed the case after the union filed a charge of prohibited practice, alleging that the transfer was retaliatory. The hearing officer initially found that while the transfer was an adverse employment action and the union had established a prima facie case of retaliation, the city had rebutted this by producing evidence of Babcock's insubordination and misconduct. The hearing officer concluded that the city's reasons for the transfer were legitimate and dismissed the complaint.Upon appeal, the CERB disagreed with the hearing officer's conclusion, finding that the city failed to produce evidence that Babcock's misconduct was the reason for his transfer. The CERB determined that the transfer was indeed retaliatory and ordered that Babcock be reinstated to his previous position.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the CERB's decision. The court held that Babcock's transfer constituted an adverse employment action despite the pay increase, as it resulted in a material disadvantage in the terms and conditions of his employment. The court also concluded that a generally good work record is not a necessary element to establish a prima facie case of retaliation. The city's failure to produce evidence linking Babcock's misconduct to the transfer decision meant that the union's prima facie case of retaliation remained unrebutted. View "City of Newton v. Commonwealth Employment Relations Board" on Justia Law

In a joint trial, Markeese Mitchell, Pedro Ortiz, and Terrance Pabon were convicted of second-degree murder. Years later, they moved to interview a juror, alleging bias and concealment of material information during jury selection. The motion was denied, and the convictions were affirmed on appeal. Subsequently, the defendants filed motions for a new trial, citing additional evidence of the same juror's alleged bias. The motion judge conducted an evidentiary hearing, where the juror testified, and then denied the new trial motions. The defendants also moved to disqualify the trial judge, arguing a conflict of interest due to the judge's professional relationship with the prosecutor from their original trial, who had since become a Superior Court judge. This motion was also denied.The Appeals Court affirmed the orders denying the motions for a new trial and for disqualification. The Supreme Judicial Court granted further appellate review. The defendants argued that they were entitled to a new trial because the juror failed to provide an honest response to a material question during empanelment, and an honest response would have provided valid grounds for a challenge for cause. They also argued that the trial judge should have been disqualified due to a conflict of interest.The Supreme Judicial Court concluded that the trial judge did not abuse her discretion in denying the motions for a new trial or the motion for disqualification. The Court found that the juror's inaccurate answer was not dishonest and did not demonstrate bias. The Court also found that the trial judge's professional relationship with the former prosecutor did not create an appearance of partiality. Therefore, the orders denying the motions for a new trial and for disqualification were affirmed. View "Commonwealth v. Mitchell" on Justia Law

Two children in the custody of the Department of Children and Families (DCF) appealed the dismissal of guardianship petitions filed by their great-aunt and great-uncle, who reside in Pennsylvania. The Juvenile Court dismissed the petitions, citing the Interstate Compact on the Placement of Children (ICPC), as Pennsylvania had denied the placement due to the great-uncle's felony convictions from the 1990s. The children argued that the ICPC does not apply to out-of-state relatives seeking guardianship, while DCF contended that the appeal should be dismissed because the great-aunt and great-uncle, who are indispensable parties, did not appeal the dismissal.The Juvenile Court granted DCF's motion to dismiss the guardianship petitions, concluding that allowing the guardianship would violate the ICPC. The court noted that Pennsylvania's denial was based on the great-uncle's ineligibility to work or volunteer with children due to his felony convictions. The children filed a motion for reconsideration, which was denied. They then filed timely notices of appeal, but the great-aunt and great-uncle did not.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the absence of the great-aunt and great-uncle, who are indispensable parties, compelled the dismissal of the appeal. The court emphasized that it could not proceed without the relatives, whose rights would be affected by the decision. Consequently, the appeal was dismissed. View "Guardianship of Wilson" on Justia Law

A child was temporarily removed from her parents' care shortly after birth and placed in the custody of the Department of Children and Families (DCF) due to concerns about domestic violence. DCF sought to vaccinate her according to an age-based immunization schedule, but her parents, practicing Rastafarians, objected on religious grounds. A Juvenile Court judge allowed DCF to facilitate vaccinations for the child. The parents sought to stop future vaccinations, arguing that vaccinating their child over their religious objections violated their constitutional rights.The Juvenile Court judge found that the parents' religious beliefs were outweighed by the child's best interests and allowed DCF to vaccinate the child. The parents petitioned the Appeals Court for interlocutory relief, which was denied. The parents then appealed to the Appeals Court panel, and the child sought direct appellate review in the Supreme Judicial Court, which was granted.The Supreme Judicial Court of Massachusetts held that the order allowing the child to be vaccinated violated the parents' constitutional rights. The court concluded that the parents' sincerely held religious beliefs were substantially burdened by DCF's vaccination efforts. The court applied the State constitutional protections afforded to parents exercising their free exercise rights and determined that DCF failed to demonstrate that exempting the child from vaccinations would substantially hinder the fulfillment of DCF's interests in promoting child health. The court noted the Commonwealth's allowance of religious exemptions from vaccination requirements for parents who have not lost custody and DCF's inconsistent exercise of its authority to order vaccinations for children in its care. The order allowing the joint motion by DCF and the child to facilitate the vaccination of the child was reversed. View "Care and Protection of Eve" on Justia Law

In the early morning of March 24, 2015, Kenneth Lopez was shot and killed on Dwight Street in Springfield. His body was discovered the next morning. Lee Manuel Rios was arrested nine days later and charged with murder, conspiracy to commit murder, and several firearms offenses. In February 2018, a jury convicted Rios of first-degree murder with extreme atrocity or cruelty and deliberate premeditation, sentencing him to life in prison without parole.Rios appealed his convictions, the denial of his motion to suppress mail intercepted by the jail, the denial of his posttrial motion for a new trial, and sought relief under G. L. c. 278, § 33E. He also sought a new trial on several firearms convictions in light of the decision in Commonwealth v. Guardado.The Massachusetts Supreme Judicial Court reviewed the case. The court found no reason to exercise its extraordinary power to grant a new trial or reduce Rios's conviction of first-degree murder. The court affirmed the murder conviction and other firearm offenses, as well as the orders denying his pretrial motion to suppress and posttrial motion for a new trial. However, the court vacated Rios's convictions under G. L. c. 269, § 10 (a) and (h) and remanded those charges for a new trial, in accordance with the decision in Guardado II. View "Commonwealth v. Rios" on Justia Law

The defendant was convicted by a jury of aggravated rape of a child and indecent assault and battery on a child under fourteen years old. The charges stemmed from the defendant's rape and sexual assault of his twelve-year-old granddaughter. The victim testified that the defendant assaulted her in his bedroom while her mother was out of the house. The victim reported the assault to a Department of Children and Families (DCF) social worker, which led to police involvement and the collection of DNA evidence from the bedding.The Superior Court admitted the DNA evidence, which confirmed the presence of the defendant's DNA but excluded the victim's DNA. The defense argued that the DNA evidence contradicted the victim's testimony and suggested that the victim fabricated the assault after seeing the defendant with his girlfriend. The jury convicted the defendant on all counts, and the defendant appealed.The Supreme Judicial Court of Massachusetts reviewed the case. The defendant argued that his confrontation rights were violated because a reviewing analyst testified about the findings of a nontestifying analyst concerning DNA testing. The court agreed that the testimony was admitted in error but concluded that the error did not result in a substantial risk of a miscarriage of justice. The court also addressed the defendant's argument that the judge abused his discretion in admitting evidence of a prior sexual assault by the defendant on the victim. The court found that the judge acted within his discretion in admitting the prior bad act evidence.The Supreme Judicial Court affirmed the judgments, holding that the admission of the DNA evidence and the prior bad act evidence did not warrant a new trial. The court concluded that the errors did not significantly impact the trial's outcome, given the overall strength of the victim's testimony and the limited nature of the prior bad act evidence. View "Commonwealth v. Nascimento-Depina" on Justia Law

The defendant crashed his vehicle into a State police cruiser parked in the breakdown lane on Interstate Route 90, resulting in the death of a trooper. The defendant was convicted of involuntary manslaughter, misdemeanor motor vehicle homicide by means of negligent or reckless operation, operating a motor vehicle so as to endanger the lives or safety of the public, and operating an uninsured motor vehicle. The defendant appealed, arguing that the Legislature did not authorize multiple punishments for involuntary manslaughter, motor vehicle homicide, and operating to endanger arising from the same act. He also contended that the evidence was insufficient to sustain his involuntary manslaughter conviction and that his trial counsel was ineffective.The Superior Court judge denied the defendant's motion for a new trial. The Appeals Court reversed the convictions of motor vehicle homicide and operating to endanger, holding that the Legislature did not intend to impose multiple punishments based on the same act for those offenses where a defendant is also convicted of involuntary manslaughter. The Appeals Court upheld the involuntary manslaughter conviction and rejected the defendant's arguments regarding the insufficiency of evidence and ineffective assistance of counsel.The Supreme Judicial Court of Massachusetts granted further appellate review. The court reaffirmed its holding in Commonwealth v. Jones, which precludes multiple punishments for involuntary manslaughter, motor vehicle homicide, and operating to endanger based on the same act. The court affirmed the defendant's convictions of involuntary manslaughter and operating an uninsured motor vehicle but reversed the convictions of motor vehicle homicide and operating to endanger. The court also affirmed the denial of the defendant's motion for a new trial, finding no ineffective assistance of counsel. View "Commonwealth v. Njuguna" on Justia Law