Justia Massachusetts Supreme Court Opinion Summaries

The plaintiff, the register of deeds for Norfolk County, filed a lawsuit against the county commissioners for Norfolk County, seeking declaratory, mandamus, and injunctive relief regarding funding and personnel matters within the registry of deeds. The dispute centered on hiring a new chief information officer and the funding for that position. While this litigation was ongoing, the plaintiff requested the county director to transfer funds within the registry's budget to cover legal fees for the personnel litigation. The county director denied these requests, prompting the plaintiff to file a second lawsuit for declaratory, mandamus, and injunctive relief.In the Superior Court, the plaintiff moved for summary judgment regarding the budget transfers, and the defendants cross-moved for summary judgment. The judge granted summary judgment in favor of the plaintiff, ruling that under G. L. c. 35, § 32, the plaintiff had the authority to transfer funds within a main group of the budget based on his opinion of public necessity and convenience. The defendants appealed this decision.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the Superior Court's decision. The court held that the statutory language of G. L. c. 35, § 32, clearly grants the authorized official the discretion to transfer funds within a main group based on their opinion of public necessity and convenience. The court found that the plaintiff's opinion was sufficient justification for the transfers and that the defendants' interference was unlawful. The court ordered that any outstanding amounts that should have been transferred be specifically authorized by the defendants and that the defendants refrain from hindering lawful transfers within the Contractual Services main group in the future. View "Register of Deeds for Norfolk County v. County Director for Norfolk County" on Justia Law

The taxpayer, 480 McClellan LLC, leased property from the Massachusetts Port Authority (Massport) to construct and operate a cargo facility. The property, located in East Boston, was previously taxable before Massport acquired it in 1990. In 2017, the City of Boston began taxing the property, and the taxpayer sought abatements for the tax years 2017 through 2020, which were denied by the city's board of assessors.The taxpayer appealed to the Appellate Tax Board, arguing that section 53 of the 1993 supplemental appropriations bill exempted it from taxation because the property was used for "air transportation purposes." The board invited the parties to address whether section 53 had amended section 17 of the Massport enabling act, which governs the taxation of Massport lessees. The board concluded that section 53 was not enacted because the Senate did not finalize its reconsideration of the Governor's veto before the end of the 1993 legislative session. The board also determined that the property was leased for "business purposes" under section 17, making the taxpayer subject to taxation.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the board's decision. The court held that the Senate's initial vote to override the Governor's veto of section 53 was not final due to a timely motion to reconsider, which was not resolved before the legislative session ended. Therefore, section 53 did not amend section 17. The court also upheld the board's interpretation that "business purposes" under section 17 includes commercial, for-profit activities, and found that the taxpayer leased the property for such purposes. Consequently, the taxpayer was subject to taxation under section 17. View "480 McClellan LLC v. Board of Assessors of Boston" on Justia Law

The defendant was charged with three counts: second-degree murder, manslaughter while operating a motor vehicle under the influence of alcohol, and leaving the scene of personal injury resulting in death. The trial lasted over two months, involving extensive evidence and numerous witnesses. After deliberating for several days, the jury sent three notes to the judge indicating they were unable to reach a unanimous verdict. The judge declared a mistrial based on the jury's final note, which stated that further deliberation would be futile and would force jurors to compromise their deeply held beliefs.The defendant filed a motion to dismiss, arguing that posttrial accounts from several jurors indicated they had unanimously agreed she was not guilty on two of the three charges and were deadlocked only on the remaining charge. The trial judge denied the motion, reasoning that no verdict was announced in open court, and thus, there was no acquittal. The judge also rejected the request for a posttrial juror inquiry, stating that it would involve an impermissible inquiry into the substance of the jury's deliberations.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the trial judge's decision. The court held that the trial judge acted within her discretion in declaring a mistrial based on manifest necessity, given the jury's repeated statements of deadlock and the risk of coercion in further deliberations. The court also concluded that posttrial juror accounts could not retroactively alter the trial's outcome, as no verdict was returned and affirmed in open court. Therefore, the defendant's motion to dismiss and request for a posttrial juror inquiry were properly denied. View "Read v. Commonwealth" on Justia Law

The defendants, Nicholas Sicellon and Jerion Moore, were indicted for first-degree murder and unlicensed possession of a firearm. Their first trial in December 2021 ended in a mistrial due to a deadlocked jury. In their second trial in July 2022, the jury again could not reach a unanimous verdict, leading the trial judge to declare a mistrial after the jury reported twice that they were deadlocked. The defendants filed motions to dismiss the charges on double jeopardy grounds, arguing that the mistrial was declared without manifest necessity and that the evidence was insufficient to identify them as the perpetrators. These motions were denied.The defendants then petitioned a single justice of the Supreme Judicial Court for extraordinary relief under G. L. c. 211, § 3, which was also denied. They appealed this decision, arguing that the trial judge improperly declared a mistrial without manifest necessity and that the evidence was insufficient to support their identification as the shooters.The Supreme Judicial Court reviewed the case and concluded that the trial judge did not abuse her discretion in declaring a mistrial. The judge had given careful consideration to the alternatives and determined that further deliberations would be coercive given the jury's unequivocal statements of deadlock. The court also found that the evidence presented at the second trial was sufficient for a rational trier of fact to identify the defendants as the perpetrators beyond a reasonable doubt.The Supreme Judicial Court affirmed the single justice's denial of the defendants' petitions, holding that there was no clear error of law or abuse of discretion in the denial of relief. The judgments of the single justice were affirmed, allowing the Commonwealth to retry the defendants. View "Sicellon v. Commonwealth" on Justia Law

The defendant, a police captain in the West Springfield police department, was found guilty of obtaining an unwarranted privilege with fraudulent intent by using over $1,000 from the police department's evidence room to pay his home mortgage. The defendant was sentenced to a one-year term of probation. He appealed his conviction on the grounds that the statutes under which he was convicted were unconstitutionally vague and that the evidence was insufficient to prove he acted with fraudulent intent or that the unwarranted privilege had a fair market value of over $1,000 in any twelve-month period.The Superior Court denied the defendant's pretrial motion to dismiss the indictment. After a jury-waived trial, the trial judge found the defendant guilty and denied his motion for a required finding of not guilty. The defendant then appealed to the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court affirmed the conviction, holding that the statutes in question were not unconstitutionally vague. The court found that the terms "unwarranted privilege" and "fraudulent intent" provided sufficient notice of prohibited conduct to a person of reasonable intelligence. The court also concluded that the evidence was sufficient to prove the defendant acted with fraudulent intent, as he had secreted money from the evidence room to pay his mortgage and made false statements to investigators. Additionally, the court determined that the fair market value of the unwarranted privilege exceeded $1,000, based on the face value of the money taken from the evidence room. View "Commonwealth v. Spaulding" on Justia Law

The plaintiffs, Jeffrey Cubberley and Philip Seaver, filed a lawsuit against The Commerce Insurance Company, seeking declaratory relief and compensation for alleged breach of contract. They claimed that Commerce was obligated to cover "inherent diminished value" (IDV) damages to their vehicles, which were damaged in collisions caused by Commerce's insured drivers. Commerce paid for the repairs but refused to compensate for IDV damages, leading the plaintiffs to argue that their vehicles were worth less in the resale market post-repair.The plaintiffs initially filed their lawsuit in the Superior Court, which was later transferred to the business litigation session. The case was stayed pending the outcome of McGilloway v. Safety Ins. Co., which held that IDV damages were recoverable under the 2008 standard Massachusetts automobile policy. After the stay was lifted, the plaintiffs filed a second amended complaint. Commerce moved to dismiss the claims, arguing that the 2016 standard policy excluded IDV damages. The motion judge granted the dismissal, concluding that the policy did not cover IDV damages and that the plaintiffs failed to allege facts suggesting an entitlement to relief. The plaintiffs appealed, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court affirmed the dismissal, holding that the plaintiffs lacked standing to pursue their breach of contract claims because they had not obtained final judgments against the insureds, as required by G. L. c. 175, § 113, and G. L. c. 214, § 3 (9). Additionally, the court found that part 4 of the 2016 standard policy explicitly excluded coverage for IDV damages to third-party vehicles. The court also determined that neither G. L. c. 90, § 34O, nor the decision in McGilloway provided a legal basis requiring insurers to cover IDV damages under the 2016 standard policy. Thus, the plaintiffs' complaint did not plausibly establish an entitlement to relief. View "Cubberley v. The Commerce Insurance Company" on Justia Law

In this case, the defendant was on trial for murder. During jury deliberations, an argument between two jurors led to allegations of racial bias. The judge conducted a limited inquiry into the matter but did not fully investigate the allegations. The defendant was convicted of murder in the second degree, unlawful possession of a firearm, and unlawful possession of a loaded firearm.The case was initially tried in the Superior Court Department, where the defendant was found guilty. The defendant appealed, and the Appeals Court affirmed the conviction. The Supreme Judicial Court then granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the trial judge's limited inquiry into the allegations of racial bias was insufficient. The court held that the judge should have conducted a more thorough investigation to determine whether the alleged racial bias affected the jury's impartiality. The court emphasized the importance of ensuring a fair and impartial trial, free from racial bias.As a result, the Supreme Judicial Court vacated the defendant's convictions and remanded the case for a new trial. The court's main holding was that the trial judge's failure to adequately investigate the allegations of racial bias created a substantial risk of a miscarriage of justice, warranting a new trial. View "Commonwealth v. Vasquez" on Justia Law

A juvenile was involved in an altercation at the Barnstable District and Juvenile Court, where he was charged with disorderly conduct and assault and battery. The incident was captured on video, showing the juvenile and the victim engaging in a physical fight. The juvenile had a prior continuance without a finding (CWOF) after admitting to sufficient facts for an assault and battery charge.The Juvenile Court adjudicated the juvenile delinquent on both charges and sentenced him to one year of probation for each. The juvenile appealed, arguing that the court lacked jurisdiction over the disorderly conduct charge because a CWOF after an admission to sufficient facts should not count as a prior offense under G. L. c. 119, § 52. The Appeals Court did not review the case as it was transferred to the Supreme Judicial Court.The Supreme Judicial Court held that a CWOF entered after an admission to sufficient facts is sufficient to establish a first offense under § 52. Therefore, the Juvenile Court had jurisdiction over the disorderly conduct charge. The court also found that the evidence was sufficient to support the juvenile's adjudications of delinquency for both disorderly conduct and assault and battery. The court affirmed the adjudications, concluding that the juvenile did not act in self-defense and that his actions met the criteria for disorderly conduct. View "Commonwealth v. Fayad F." on Justia Law

The Commonwealth sought to civilly commit a prisoner, previously convicted of a sexual offense, as a "sexually dangerous person" (SDP) under Massachusetts law. The process required expert testimony to establish probable cause and qualified examiners to determine if the case should proceed to trial. The plaintiff, George Mackie, was initially adjudicated as an SDP based on expert reports and testimony, but this decision was later vacated on appeal due to prejudicial error.Mackie then filed separate civil actions against Dr. Katrin Rouse-Weir, a probable cause expert, and Dr. Robert Joss, a qualified examiner, alleging they submitted false reports and testimony. Both defendants moved to dismiss the complaints, claiming immunity. Superior Court judges granted the motions, concluding that the defendants were entitled to absolute quasi-judicial immunity. Mackie appealed these decisions.The Appeals Court reversed the dismissals, ruling that the experts were entitled only to qualified immunity, not absolute quasi-judicial immunity. The Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court held that qualified examiners like Joss are entitled to absolute quasi-judicial immunity due to their essential and independent role in the judicial process. The court also concluded that probable cause experts like Rouse-Weir are protected by the litigation privilege, which shields them from liability for their statements made during judicial proceedings. Consequently, the court affirmed the Superior Court judgments dismissing Mackie's complaints against both experts. View "Mackie v. Rouse-Weir" on Justia Law

The defendant was convicted of second-degree murder for the killing of Paul Finegan at a backyard birthday party in Springfield. The defendant arrived at the party, where the victim, who was uninvited, became upset upon seeing him. After a brief argument, the defendant shot the victim in the head and fled the scene. The victim was unarmed, and the defendant did not testify at trial. The defense argued that the eyewitnesses were not credible and had been pressured by the police.The case was initially tried in the Superior Court, where the defendant was found guilty of second-degree murder. The defendant filed a motion for a new trial, arguing that a voir dire question asked by the prosecutor during jury selection was improper and deprived him of an impartial jury. The trial judge denied the motion, and the Appeals Court affirmed the conviction and the denial of the motion for a new trial.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the prosecutor's voir dire question, which asked prospective jurors if they could convict the defendant based on eyewitness testimony without forensic evidence, was improper. However, the court concluded that this error did not create a substantial risk of a miscarriage of justice. The court noted that the evidence against the defendant was overwhelming, and the jury had been properly instructed on the burden of proof and the evaluation of eyewitness testimony. The court affirmed the defendant's conviction and the order denying his motion for a new trial. View "Commonwealth v. Montgomery" on Justia Law