Justia Massachusetts Supreme Court Opinion Summaries

The defendant was convicted of operating a motor vehicle after his license had been revoked. The revocation was due to a prior conviction for motor vehicle homicide and operating under the influence (OUI). The defendant argued that his motion to dismiss the complaint should have been allowed because the citation was not issued at the time and place of the violation, as required by the "no-fix" statute. The police learned of the violation weeks later through a television news report and issued the citation after investigating the report.In the Dedham Division of the District Court Department, the defendant's motion to dismiss was denied. The judge found that additional time was reasonably necessary to investigate the violation. The defendant's motion for reconsideration was also denied. At trial, the judge found the defendant guilty and sentenced him to eighteen months in a house of correction. The defendant appealed, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts affirmed the lower court's decision. The court held that the delay in issuing the citation was justified because additional time was reasonably necessary to investigate the violation. The court also found that the evidence was sufficient to prove that the defendant operated a motor vehicle after his license had been revoked and before it was restored. The court rejected the defendant's argument that the penalty only applied during the pendency of the revocation period, clarifying that the penalty continues to apply until the license or right to operate is restored. The judgment was affirmed. View "Commonwealth v. Foley" on Justia Law

The defendant was charged with carrying a firearm without a license, carrying a loaded firearm without a license, and possession of ammunition without a firearm identification card following a traffic stop where police found a loaded firearm in his pocket. At trial, the Commonwealth sought to prove the defendant lacked a license to carry a firearm through the testimony of a Department of Criminal Justice Information Services (DCJIS) employee. The employee testified that a search of the DCJIS-maintained Statewide database using the defendant's name and a birth date provided by the district attorney's office returned no results. However, the judge did not admit the testimony regarding the birth date as evidence of the defendant's actual birth date due to the witness's lack of personal knowledge, and the Commonwealth did not introduce other evidence establishing the defendant's birth date.The trial judge denied the defendant's motion for a required finding of not guilty and convicted him of possessing a firearm without a license and possessing ammunition without a firearm identification card. The defendant appealed, challenging the sufficiency of the Commonwealth's proof of nonlicensure and arguing that the testimony violated his right to confront witnesses under the Sixth Amendment and the Massachusetts Declaration of Rights.The Supreme Judicial Court of Massachusetts reviewed the case and held that a witness testifying about a search of a public records database must be familiar with the process of searching the database and the government record-keeping practices. The court found no abuse of discretion in admitting the DCJIS employee's testimony. However, the court concluded that the Commonwealth's proof of lack of licensure was insufficient because it did not introduce evidence that the birth date used to search the database was the defendant's actual birth date. Consequently, the court reversed the defendant's convictions and remanded for entry of judgments in favor of the defendant. View "Commonwealth v. Smith" on Justia Law

In January 2018, Shaquille Browder was shot and killed in a parking lot in Boston. Ralph Brown was indicted and convicted of first-degree murder based on deliberate premeditation. Brown appealed, claiming errors by judges and the prosecutor, and insufficient evidence of his guilt.The Superior Court denied Brown's pretrial motions to suppress evidence obtained from search warrants for a vehicle's infotainment system and his cell phone's location data. The court found no material misstatements or intent to deceive in the affidavits supporting the warrants. Brown's motion to dismiss the indictments, alleging grand jury impairment due to improper statements by a detective, was also denied. The court ruled that the statements did not influence the grand jury's decision to indict.The Massachusetts Supreme Judicial Court reviewed the case and upheld Brown's conviction. The court found that the evidence, including surveillance footage, cell phone records, and vehicle rental information, was sufficient to support the jury's verdict. The court also addressed Brown's claims of improper jury empanelment and prosecutorial misconduct during closing arguments. It concluded that any errors in voir dire questions about motive did not result in a substantial likelihood of a miscarriage of justice. The court determined that the prosecutor's comments during closing arguments were permissible and did not shift the burden of proof or misstate facts.The court affirmed Brown's conviction of first-degree murder but vacated his convictions for carrying a firearm without a license and carrying a loaded firearm, remanding for further proceedings consistent with recent case law. View "Commonwealth v. Brown" on Justia Law

In the early morning of August 10, 2014, the defendant entered an apartment in Lowell and fatally shot two occupants. He was convicted of felony-murder, armed home invasion, and possession of a firearm without a license. The defendant appealed, raising several arguments.The Superior Court jury found the defendant guilty of felony-murder, armed home invasion, and unlawful possession of a firearm. The defendant argued that the jury should have been instructed that the Commonwealth needed to prove the absence of mitigating circumstances for felony-murder, that the prosecutor improperly appealed to emotion, that the judge prejudged the sentences, and that defense counsel was ineffective for not presenting mitigating information at sentencing. The defendant also contended that his convictions for armed home invasion and firearm possession should be vacated.The Supreme Judicial Court of Massachusetts reviewed the case. The court vacated the armed home invasion conviction as duplicative of the felony-murder conviction and vacated the firearm possession conviction due to improper jury instructions regarding the burden of proof for licensure. The court remanded the firearm charge for further proceedings. The court affirmed the felony-murder convictions, finding no error in the jury instructions regarding mitigating circumstances, no improper appeals to emotion by the prosecutor, and no substantial likelihood of a miscarriage of justice due to the judge's sentencing comments or defense counsel's performance. The court also declined to exercise its authority to reduce the verdicts under G. L. c. 278, § 33E. View "Commonwealth v. Poum" on Justia Law

Three juveniles, Frederick F., Angela A., and Manolo M., were adjudicated delinquent on charges of resisting arrest. The events occurred on October 3, 2019, near Brockton High School, where a large crowd of students had gathered, leading to multiple altercations. Frederick yelled profanities at police officers and refused to leave the area, Angela recorded officers with her cell phone while yelling at them, and Manolo attempted to punch an officer and engaged in a physical struggle.The Juvenile Court denied Frederick's motion to dismiss the complaint for lack of probable cause and denied all three juveniles' motions for required findings of not delinquent. The Appeals Court affirmed the adjudications for resisting arrest but vacated Manolo's adjudication for assault and battery on a police officer due to an error in jury instructions.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the evidence was sufficient to support the adjudications for resisting arrest. For Frederick, the court found that the circumstances provided a basis for a good-faith judgment to arrest him for disorderly conduct. For Angela, the court concluded that her conduct of thrusting her cell phone within inches of officers' faces and resisting arrest by pulling away constituted the use of physical force. For Manolo, the court determined that his physical struggle with officers on the ground, following his aggressive actions, provided sufficient evidence of using physical force to resist arrest.The court affirmed the adjudications of delinquency for resisting arrest for all three juveniles and remanded for further proceedings on Manolo's vacated adjudication for assault and battery on a police officer. View "Commonwealth v. Manolo M." on Justia Law

The case involves the Massachusetts Insurers Insolvency Fund (MIIF) seeking cost-of-living adjustment (COLA) payment reimbursements from the Workers' Compensation Trust Fund (trust fund). MIIF, a nonprofit entity created by statute, administers and pays certain claims against insolvent insurers. Between 1989 and 2013, MIIF paid workers' compensation benefits, including COLA payments, on behalf of several insolvent insurers. MIIF filed claims with the trust fund for reimbursement of these payments, but the trust fund denied the claims, arguing that MIIF is not an "insurer" under the relevant statutes and does not participate in the trust fund.The Department of Industrial Accidents (DIA) administrative judge denied MIIF's claims, and the Industrial Accident Reviewing Board (board) affirmed the decision. The board relied on the Appeals Court's decision in Home Ins. Co. v. Workers' Compensation Trust Fund, concluding that MIIF, like the insolvent insurers, does not collect and transmit assessments to the trust fund and is therefore not entitled to reimbursement.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that MIIF is eligible for COLA-payment reimbursements. The court determined that MIIF, when taking on an insolvent insurer's covered claims, is "deemed the insurer" and has "all rights, duties, and obligations" of the insolvent insurer under G. L. c. 175D, § 5 (1) (b). The court also found that the plain language of the relevant statutes does not exclude MIIF from reimbursement eligibility and that the trust fund's funding mechanism, which is paid for by employers, supports MIIF's entitlement to reimbursement.The Supreme Judicial Court reversed the board's decision and remanded the case for further proceedings consistent with its opinion. View "Massachusetts Insurers Insolvency Fund v. Workers' Compensation Trust Fund" on Justia Law

An insurer, Arrowood Indemnity Company, entered run-off in 2003, ceasing to issue new policies but continuing to manage existing claims, including workers' compensation for a Scully Signal Company employee who sustained a second work-related injury in 2001. Arrowood sought second-injury reimbursements from the Massachusetts Workers' Compensation Trust Fund, which reimburses insurers for a portion of workers' compensation benefits paid to employees with exacerbated injuries. Arrowood and the Trust Fund settled in 2009, with Arrowood receiving reimbursements until 2013.The Department of Industrial Accidents (DIA) began denying Arrowood's reimbursement requests in 2015, citing a precedent that insurers in run-off, who no longer collect and transmit employer assessments to the Trust Fund, are ineligible for reimbursements. Arrowood's subsequent complaint in Superior Court was dismissed, and the Appeals Court affirmed the dismissal, directing Arrowood to seek administrative review. The DIA administrative judge and the Industrial Accident Reviewing Board upheld the denial, leading Arrowood to appeal to the Appeals Court.The Appeals Court reversed the Board's decision, ruling that the statutory language of the Massachusetts workers' compensation act does not preclude insurers in run-off from receiving second-injury reimbursements. The Supreme Judicial Court of Massachusetts granted further appellate review and agreed with the Appeals Court. The Court held that the plain language of the act does not exclude insurers in run-off from reimbursement eligibility and that the statutory scheme supports this interpretation. The Court reversed the Board's decision and remanded for further proceedings consistent with its opinion. View "Arrowood Indemnity Company v. Workers' Compensation Trust Fund" on Justia Law

The defendant, Manuel Diaz, was subjected to an unlawful traffic stop by Officer Mark Shlosser of the Wilbraham police department. Upon being stopped, Diaz fled in his car, lost control, and then fled on foot into the woods, where drugs were later found along his path. Diaz was charged with trafficking cocaine, and his motion to suppress the drugs and evidence of identity obtained from his car was denied.In the Superior Court, Diaz's motion to suppress was initially denied despite the judge finding the stop unjustified under art. 14 of the Massachusetts Declaration of Rights and the Fourth Amendment. The judge concluded that Diaz's flight was an independent intervening act, triggering the attenuation exception to the exclusionary rule. Diaz's motion for reconsideration was also denied after a Long hearing, where the judge reaffirmed that the attenuation exception applied.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the attenuation exception did not apply to either the art. 14 violation or the equal protection violation under arts. 1 and 10. The court found that the temporal proximity between the stop and Diaz's flight, the lack of credible justification for the stop, and the inherently flagrant nature of racially selective traffic enforcement weighed against attenuation. Consequently, the court reversed the lower court's denial of Diaz's motion to suppress the evidence obtained from the unlawful stop. View "Commonwealth v. Diaz" on Justia Law

A police officer found the defendant behind the wheel of a parked rental van in a municipal lot. The key was in the ignition, the radio was on, and there was a strong odor of alcohol. The defendant exhibited signs of intoxication, including slurred speech and bloodshot eyes. The officer observed vodka bottles in the vehicle and asked the defendant to move the van slightly to clear a tree blocking the driver's door. The defendant complied, and upon exiting the vehicle, he struggled with field sobriety tests and was arrested for operating under the influence (OUI).The defendant was tried in the Falmouth Division of the District Court Department and found guilty of OUI, fifth offense. He was also found guilty of OUI with a license suspended for OUI after a bench trial. The defendant was sentenced to three and a half years in a house of correction. The Appeals Court affirmed the convictions, and the Supreme Judicial Court granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed whether the evidence was sufficient to show that the defendant "operated" the vehicle while under the influence. The court held that the evidence was sufficient, affirming the convictions. The court explained that "operates" under the OUI statute includes any act that sets in motion the vehicle's motive power, such as turning the key in the ignition. The court concluded that the defendant's actions of turning the key and being intoxicated while in the driver's seat met the statutory definition of "operates," even though the vehicle was not moving. View "Commonwealth v. Wurtzberger" on Justia Law

Tody's Service, Inc. (Tody's), a towing company, billed Liberty Mutual Insurance Company (Liberty) a six-figure storage fee after towing and storing a vehicle involved in a fatal crash at the direction of the police. The vehicle, insured by Liberty, was held as evidence for nearly three years. After obtaining the vehicle's title, Liberty refused to pay the accrued storage charges, leading Tody's to sue Liberty to recover those fees.In the Superior Court, a judge granted summary judgment in favor of Liberty on all of Tody's claims, which included unjust enrichment, promissory estoppel, and failure to pay storage fees under G. L. c. 159B, § 6B. The judge found no evidence of unjust enrichment, ruled that § 6B does not provide a private right of action, and concluded that Tody's failed to demonstrate any actionable promise or reasonable reliance to support promissory estoppel.The Supreme Judicial Court reviewed the case and held that Liberty was not unjustly enriched as a matter of law, as there was no measurable benefit conferred on Liberty by Tody's storage of the vehicle. The court also found no evidence of reliance sufficient to support promissory estoppel, as Tody's stored the vehicle in response to a police directive, not in reliance on any promise by Liberty. Additionally, the court held that § 6B does not create a private right of action against a vehicle owner. Consequently, the Supreme Judicial Court affirmed the judgment in Liberty's favor. View "Tody's Service, Inc. v. Liberty Mutual Insurance Company" on Justia Law