Justia Massachusetts Supreme Court Opinion Summaries

The case concerns an individual who was tried on six charges involving sexual abuse of minors. At trial, the jury acquitted him on five counts relating to two minors but convicted him on one count involving a third minor. After the trial, he filed a timely notice of appeal. Subsequently, the Executive Office of the Trial Court issued a notice under the Massachusetts automatic sealing statute, informing him that records relating to the acquitted counts would be sealed unless he requested otherwise. The notice also stated that he would lose access to those records once sealed. The individual did not respond, and some records were sealed.After this, appellate counsel was appointed to represent the individual on appeal. Counsel attempted to obtain the trial records, including those pertaining to the acquitted counts, but discovered that certain documents had been sealed. Counsel then moved for access to these sealed documents, arguing that not having access would hinder effective appellate representation. The motion judge allowed only limited access—counsel could view the documents at the clerk’s office under supervision and take notes, but could not make copies. The individual submitted an affidavit authorizing counsel’s access, but the motion judge maintained the restrictions. Seeking broader access, the individual petitioned a single justice of the Supreme Judicial Court under G. L. c. 211, § 3. The single justice reserved and reported the matter to the full court.The Supreme Judicial Court of Massachusetts held that the automatic sealing statute does not preclude a defendant or the defendant’s appellate counsel from accessing the defendant’s own sealed criminal records. The court concluded that the statute’s text, legislative history, and related statutory framework support the view that sealing is aimed at precluding public access—not preventing the defendant and counsel from reviewing the records necessary for appeal. The court vacated the lower court’s order restricting access and remanded for entry of an order providing access to the sealed records. View "Gravito v. Commonwealth" on Justia Law

A student at Dearborn School in Boston was found in possession of a nine millimeter Glock pistol with six rounds of ammunition during an administrative search. The juvenile, who had previously been subject to threats and assaults while commuting to school, did not have a license to carry the firearm but did possess a valid firearm identification card. After his arrest, the juvenile was readmitted to school, graduated, and subsequently completed occupational training and part-time employment.The Suffolk County Division of the Juvenile Court Department issued a delinquency complaint charging the juvenile with unlawful possession of a firearm, carrying a loaded firearm without a license, and unlawful possession of ammunition. During plea negotiations, the juvenile recommended a continuance without a finding (CWOF) on the firearm counts, while the Commonwealth sought commitment to the Department of Youth Services (DYS) until the juvenile’s nineteenth birthday. Both parties agreed to dismiss the ammunition charge. The judge allowed the CWOF on the firearm counts and dismissed the ammunition count, rejecting the Commonwealth’s argument that a CWOF was prohibited for the firearm charge. The judge subsequently denied the Commonwealth’s motion to revise or revoke the sentence, and the Commonwealth appealed.The Supreme Judicial Court of Massachusetts reviewed whether a Juvenile Court judge may impose a CWOF for a juvenile charged with carrying a firearm without a license under G. L. c. 269, § 10 (a). The court held that the statutes governing juvenile proceedings permit the judge to impose a CWOF for this offense, as the prohibition against CWOFs applies only to certain enumerated sex offenses and not to firearm offenses under § 10 (a). The order denying the Commonwealth’s motion to revise or revoke the sentence was affirmed. View "Commonwealth v. Q." on Justia Law

The case concerns the medical treatment of a fifty-eight-year-old man who suffered a shoulder injury and subsequently died from septic shock, acute septic arthritis, metabolic acidosis, and renal failure. After his initial visit to the emergency department, he was diagnosed with rotator cuff tendinitis and cellulitis, and discharged with antibiotics. His condition worsened over several weeks, leading to multiple emergency department visits and consultations with various medical providers, including nurse practitioner Michael Collins. Collins attended to the patient on August 4-5, 2020, and discharged him after administering fluids and pain medication, advising follow-up with orthopedics. The patient returned to the hospital two days later in a deteriorated state, was diagnosed with sepsis and septic arthritis, and died shortly thereafter.The plaintiff, acting as personal representative of the decedent’s estate, filed a medical malpractice action in the Massachusetts Superior Court against several providers, including Collins. The plaintiff submitted an offer of proof supported by medical records and expert opinion, alleging that Collins failed to meet the standard of care by not recognizing symptoms of septic arthritis, failing to order appropriate imaging and bloodwork, and not admitting the patient for further treatment. Collins and other defendants requested a medical malpractice tribunal under G. L. c. 231, § 60B. The tribunal found the plaintiff’s evidence insufficient to raise a legitimate question of liability against Collins, leading to dismissal of the claims after the plaintiff did not post the required bond.The Supreme Judicial Court of Massachusetts reviewed the tribunal’s decision. It held that the tribunal erred in finding the plaintiff’s offer of proof insufficient, as the expert opinion was factually based and rooted in the medical records, and adequately raised a legitimate question of liability and causation. The Court vacated the judgment of dismissal, allowing the plaintiff’s claims against Collins to proceed without posting a bond. View "Bennett v. Collins" on Justia Law

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