Justia Massachusetts Supreme Court Opinion Summaries

A clerk-magistrate decided to allow public access to show cause hearings for individuals accused of being clients of a prostitution ring but denied media requests for the underlying complaint applications before the hearings. The accused individuals, referred to as John Does, intervened to oppose the public access decision and sought to keep the hearings private. The media outlets filed a petition in the Supreme Judicial Court for Suffolk County to challenge the clerk-magistrate's decision to withhold the complaint applications.The single justice of the Supreme Judicial Court remanded the matter to the clerk-magistrate for written findings on specific questions related to the public interest and privacy concerns. After reviewing the clerk-magistrate's responses, the single justice denied the petition, concluding that the clerk-magistrate did not commit an error of law or abuse her discretion in allowing public access to the hearings and denying access to the complaint applications.The Supreme Judicial Court affirmed the single justice's decision, holding that the clerk-magistrate acted within her discretion. The court found that the public interest in transparency and accountability outweighed the privacy interests of the accused, especially given the significant public attention and the potential for favoritism if the hearings were held privately. The court also agreed that denying access to the complaint applications was appropriate to prevent the dissemination of potentially erroneous or extraneous information before the accused had an opportunity to respond at the hearings.The court further directed the Trial Court to provide notice to the accused when a request for public access to a show cause hearing is made and to offer the accused an opportunity to respond before deciding on the request. View "Trustees of Boston University v. Clerk-Magistrate of the Cambridge Division of the District Court Department" on Justia Law

Bruce Johnson and Caroline Settino were engaged to be married, with Johnson giving Settino a $70,000 diamond engagement ring and two wedding bands. Johnson also paid for various expenses, including part of Settino's dental implant surgery. However, Johnson ended the engagement after discovering messages on Settino's phone that led him to believe she was unfaithful, although the trial judge found no evidence of an affair. Settino kept the engagement ring and wedding bands, and Johnson did not pay for the second part of Settino's dental procedure.Johnson sued to recover the engagement ring and wedding bands, and Settino counterclaimed for the cost of the dental procedure. The Superior Court judge ruled in favor of Settino, allowing her to keep the engagement ring and one wedding band, and awarded her damages for the dental procedure, including prejudgment interest from the date of Johnson's complaint. The judge found Johnson at fault for ending the engagement based on his mistaken belief of infidelity.The Appeals Court reversed the decision, ruling that Johnson was not at fault and should recover the engagement ring and wedding band. The court also found that prejudgment interest should be calculated from the date of Settino's counterclaim, not Johnson's complaint. The Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court of Massachusetts held that the concept of fault should not determine the return of engagement rings. The court adopted a no-fault approach, requiring the return of the engagement ring and wedding bands to the donor if the marriage does not occur, regardless of fault. The court also affirmed the need to recalculate prejudgment interest from the date of Settino's counterclaim. The judgment was reversed in part and remanded for recalculation of prejudgment interest. View "Johnson v. Settino" on Justia Law

The defendant, Carlos Colina, killed Jonathan Camilien in his Cambridge apartment by strangling him in a chokehold and subsequently dismembered the body. The dismembered torso was found in a duffel bag on a nearby walkway, leading investigators to the defendant's apartment where they discovered rap music lyrics describing similar acts. The defendant was convicted of first-degree murder and improper disposal of human remains. He appealed, arguing that the admission of rap lyrics and other evidence was prejudicial and that the search warrants were deficient.The Superior Court denied the defendant's pretrial motion to suppress evidence obtained from search warrants, and the trial judge admitted the rap lyrics and records of the defendant's online purchases. The jury found the defendant guilty, and he was sentenced to life in prison without parole for the murder and six months for improper disposal of human remains.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the convictions. The court held that the rap lyrics were admissible as they were relevant to the defendant's state of mind and intent, and their probative value outweighed any prejudicial effect. The search warrants were found to be supported by probable cause and sufficiently particular. The court also concluded that the trial judge's instructions to the jury were proper and that any errors in the prosecutor's closing argument or the exclusion of certain jury instructions were not prejudicial. The court found no basis for relief under G. L. c. 278, § 33E, and affirmed the judgments. View "Commonwealth v. Colina" on Justia Law

The case involves the interpretation of the Massachusetts Principal and Income Act (MPIA) in relation to trusts established under the will of Helyn W. Kline. Kline's will created separate trusts for her daughters, including Denise Jo Levy, who is the income beneficiary of the trusts at issue here. The will allows the trustees to distribute net income to Levy and, under extraordinary circumstances, to distribute principal in emergencies. Levy's three sons are the remainder beneficiaries. The trustee, Robert Friedman, pursued a total growth investment strategy that increased the trust principal significantly more than the income.In the Probate and Family Court, Peter Judson, one of Levy's sons, filed a petition alleging improper distributions to Levy exceeding the trusts' net income. The trustee justified the distributions by exercising the power to adjust between principal and income under the MPIA, arguing it was necessary to treat all beneficiaries fairly. The Probate and Family Court judge granted summary judgment in favor of the trustee, finding no abuse of discretion in the trustee's actions.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the MPIA permits a trustee to adjust between principal and income if the trust instrument does not clearly deny this power. The court found that Kline's will did not explicitly prohibit the trustee from making such adjustments. The court also concluded that the trustee did not abuse his discretion in exercising the power to adjust, as he considered relevant factors, including the intent of the testator and the needs of the beneficiaries. The court affirmed the Probate and Family Court's decision, allowing the trustee's adjustments and distributions to Levy. View "In the Matter of the Trusts under the Will of Kline" on Justia Law

The plaintiff, Kathleen Vita, alleged that New England Baptist Hospital (NEBH) and Beth Israel Deaconess Medical Center, Inc. (BIDMC) violated the Massachusetts wiretap act by collecting and transmitting her browsing activities on their websites to third parties for advertising purposes without her consent. Vita accessed information about doctors and medical conditions on the hospitals' websites and claimed these interactions were "wire communications" protected by the wiretap act. She did not allege that private patient records or messages to healthcare providers were intercepted.The Superior Court denied the hospitals' motions to dismiss Vita's complaints, leading to the hospitals' appeal. The Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the term "communication" in the wiretap act is ambiguous as applied to web browsing activities. The court found that the legislative history of the wiretap act focused on the secret interception of person-to-person conversations and messaging, particularly private ones, and did not clearly extend to interactions with websites. Given this ambiguity, the court applied the rule of lenity, which requires that any ambiguity in a criminal statute be resolved in favor of the defendant. Consequently, the court concluded that the wiretap act does not unambiguously prohibit the interception of web browsing activities and reversed the Superior Court's denial of the hospitals' motions to dismiss. View "Vita v. New England Baptist Hospital" on Justia Law

On the night of July 1, 2015, the defendant and his accomplice attempted to rob three women working as escorts at different hotels. The first woman denied them entry, the second was robbed at gunpoint, and the third was shot and killed. The defendant and his accomplice were tried jointly, and a jury convicted them of first-degree murder based on felony-murder, among other charges.The Superior Court found the defendant guilty on all charges, including murder in the first degree, attempted armed robbery, unlawful possession of a firearm, armed robbery, home invasion, and armed assault in a dwelling. The defendant appealed, arguing errors in jury selection, improper identification by a police officer, erroneous jury instructions, and the denial of an accident instruction. He also contended that his firearm conviction should be vacated based on a recent court decision.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the trial judge did not abuse discretion in dismissing two jurors for cause due to their lack of comprehension. The court found that the police officer's identification of the defendant in surveillance footage was admitted in error but did not prejudice the defendant due to the overwhelming evidence against him. The court also ruled that the jury instructions were consistent with legal standards and that the defendant was not entitled to an accident instruction due to lack of evidence. The court vacated the defendant's conviction for unlawful possession of a firearm and remanded for a new trial on that charge. The conviction for attempted armed robbery was vacated as duplicative, but the remaining judgments were affirmed. View "Commonwealth v. Jeune" on Justia Law

The case involves Roberto Cruz, who was convicted of two counts of indecent assault and battery on a child under the age of fourteen. The incidents occurred when Cruz, nearly sixty years old, hugged and kissed a thirteen-year-old girl, Jane, without her consent. Cruz was also charged with child enticement and simple assault and battery, but the latter charge was dismissed by the Commonwealth before the trial. The jury acquitted Cruz of child enticement and one count of indecent assault and battery but convicted him of the other two counts.Cruz appealed his convictions, arguing that the evidence was insufficient to prove the assaults were indecent. The Massachusetts Appeals Court agreed, reversing his convictions on the grounds that the conduct did not meet the statutory definition of indecent assault and battery. Following this reversal, Cruz filed a civil lawsuit seeking compensation for wrongful conviction under G. L. c. 258D. The Commonwealth moved for summary judgment, arguing that the reversal did not establish Cruz's innocence of the simple assault and battery charge, which had been dismissed earlier.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the eligibility for compensation under G. L. c. 258D is limited to felony convictions and does not include misdemeanors like simple assault and battery. Therefore, the court affirmed the Superior Court's denial of the Commonwealth's motion for summary judgment and remanded the case for further proceedings. The court concluded that Cruz met the eligibility requirements for compensation as the reversal of his felony convictions tended to establish his innocence of those charges. View "Cruz v. Commonwealth" on Justia Law

The case involves a probationer who was arrested during a traffic stop and subsequently charged with possession of cocaine with intent to distribute and unlawful possession of a firearm. During the traffic stop, a state trooper observed the vehicle speeding and making unsafe lane changes. Upon stopping the vehicle, the trooper noticed suspicious behavior from the back seat passenger and found drugs and a firearm in the vehicle. The probationer was found to have thrown a bag containing drugs to the back seat passenger as the vehicle was being pulled over.The Superior Court judge found the probationer in violation of his probation conditions, revoked his probation, and sentenced him to state prison. The probationer appealed, arguing that the evidence was insufficient to prove he possessed cocaine with intent to distribute and unlawfully possessed a firearm. He also claimed ineffective assistance of counsel for not moving to suppress the evidence on equal protection grounds, alleging racial animosity by the state trooper.The Supreme Judicial Court of Massachusetts reviewed the case and upheld the lower court's decision. The court found sufficient evidence to support the probation violation, including the possession and intent to distribute cocaine and the unlawful possession of a firearm. The court also rejected the claim of ineffective assistance of counsel, stating that the exclusionary rule does not generally apply to probation revocation proceedings and that the counsel's performance did not fall below the standard of an ordinary fallible lawyer.The court affirmed the revocation of probation and the denial of the motion for a new hearing. View "Commonwealth v. Gelin" on Justia Law

The defendant was involved in a kidnapping scheme orchestrated by James Feeney, who sought revenge against the victim, James Robertson, due to a romantic rivalry. Feeney enlisted the help of his cousin Alfred Ricci and the defendant, who was Feeney's car mechanic. Disguised as probation officers, the defendant and Ricci went to the victim's home, falsely claimed they were taking him for a random drug test, and brought him to Ricci's garage where Feeney was waiting. The victim was restrained in a metal chair bolted to the floor. Feeney later inflicted serious bodily injury on the victim, who was eventually found dead.The defendant was indicted for kidnapping, conspiracy, murder, and aggravated kidnapping. At trial, the judge denied the defendant's motion for a required finding of not guilty on the aggravated kidnapping charge. The jury found the defendant guilty of involuntary manslaughter, conspiracy to kidnap, and aggravated kidnapping. The defendant was sentenced to 25-30 years for aggravated kidnapping, with concurrent sentences for manslaughter and conspiracy. The Appeals Court affirmed the conviction, but a dissenting opinion argued that the rule of lenity should apply due to ambiguity in the statute.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the statute requires the dangerous weapon to be used to inflict serious bodily injury. The court found that the jury instructions were erroneous and prejudicial, as they allowed for a conviction without proving the weapon was used to inflict injury. The court vacated the defendant's conviction of aggravated kidnapping and remanded the case for further proceedings, allowing the Commonwealth to either move for sentencing on the lesser included offense of kidnapping or retry the defendant on the aggravated kidnapping charge. View "Commonwealth v. Morrison" on Justia Law

The defendant is alleged to have raped eight women by luring heavily intoxicated women into his vehicle under the guise of being a rideshare operator, then raping them after they passed out, often recording the assaults. He was indicted on multiple charges across three separate dockets in the Superior Court, including aggravated rape, indecent assault and battery, kidnapping, and photographing an unsuspecting nude person. Initially, cash bail was set, but later increased. The Commonwealth moved for pretrial detention based on dangerousness under General Laws c. 276, § 58A, which was granted after hearings.The defendant filed several motions for bail review and reconsideration of his pretrial detention, all of which were denied by the Superior Court. The motion judge concluded that rape qualifies as a predicate offense under the force clause of § 58A because it involves the use of force. The defendant then appealed to the Supreme Judicial Court for Suffolk County, arguing that rape should not be considered a predicate offense under § 58A and that the evidence did not warrant his detention.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The court held that rape, as defined under G. L. c. 265, § 22, qualifies as a predicate offense under the force clause of § 58A because it inherently involves physical force. The court distinguished rape from other offenses like indecent assault and battery and statutory rape, which do not necessarily involve physical force. The court emphasized that the act of forced penetration, regardless of the victim's capacity to consent, constitutes physical force sufficient to meet the requirements of § 58A. The judgment of the single justice denying the defendant's emergency petition for relief was affirmed. View "Campbell v. Commonwealth" on Justia Law