Justia Massachusetts Supreme Court Opinion Summaries

The plaintiff, Steven Luppold, filed a medical malpractice lawsuit after an above-the-knee amputation of his left leg. He alleged that the negligence of three healthcare providers—Susan Hanlon, a registered nurse; Charles Loucraft, a physician assistant; and Carlos Flores, a nurse practitioner—led to his injury. Luppold visited the emergency department at Lowell General Hospital twice in March 2015, complaining of severe foot pain and discoloration. Despite these symptoms, he was discharged without proper diagnosis or treatment, leading to the eventual amputation.In the Superior Court, a jury awarded Luppold $20 million in damages, finding Hanlon, Loucraft, and Flores negligent. Hanlon moved for judgment notwithstanding the verdict, to set aside the verdict, or for remittitur, arguing that the trial judge erred in not allowing cross-examination about a high-low settlement agreement between Loucraft and Flores, and that the jury instructions on factual causation were incorrect. The trial judge denied her motion, and Hanlon appealed.The Supreme Judicial Court of Massachusetts reviewed the case. The court found no abuse of discretion in the trial judge's decision to exclude cross-examination about the high-low settlement agreement, as Hanlon failed to demonstrate how the agreement caused bias or changed testimony. The court also upheld the jury instructions on factual causation, determining that they correctly conveyed the "but-for" causation standard required by law. Additionally, the court rejected Hanlon's argument that she was entitled to judgment notwithstanding the verdict, finding sufficient evidence that her actions fell below the standard of care and contributed to Luppold's injury.Finally, the court affirmed the assessment of prejudgment interest on the entire damages award, including future pain and suffering, as required by Massachusetts law. The judgment and the order denying Hanlon's posttrial motions were affirmed. View "Luppold v. Hanlon" on Justia Law

The plaintiff filed a complaint in the Land Court regarding a property in Duxbury, claiming ownership following a foreclosure sale. The defendants, who had executed a mortgage in favor of the plaintiff's predecessor, refused to vacate the property. The Land Court judge ruled in favor of the plaintiff, declaring them the lawful owner. The defendants appealed this decision.Subsequently, the plaintiff filed a summary process complaint in the Housing Court to gain possession of the property and requested use and occupancy payments from the defendants during the litigation. The Housing Court judge granted this request but stayed the proceedings pending the appeal of the Land Court judgment. The defendants sought interlocutory relief from a single justice of the Appeals Court, who vacated the Housing Court's order, stating that the Housing Court judge had not determined ownership.The plaintiff renewed their motion in the Housing Court, which was again granted, with the judge explicitly relying on the Land Court's judgment under the doctrine of res judicata. The defendants again sought relief from the single justice, who vacated the order, arguing that the Housing Court judge's reliance on the appealed Land Court judgment was improper. The plaintiff was granted leave to appeal to a full panel of the Appeals Court, and the Supreme Judicial Court transferred the case on its own motion.The Supreme Judicial Court held that a judge hearing a summary process action for possession may rely on a final judgment of the Land Court regarding ownership, even if an appeal is pending. The court confirmed that the Land Court's judgment had preclusive effect, allowing the Housing Court judge to order interim use and occupancy payments. The order of the single justice was reversed, and the defendants' petition for relief was denied. View "TJR Services LLC v. Hutchinson" on Justia Law

In 2013, an eleven-year-old juvenile was charged with rape of a child by force and assault and battery on a child with substantial injury after allegedly biting his four-year-old cousin's penis. The rape charge was dismissed, and the juvenile was placed on one year of pretrial probation for the reduced charge of simple assault and battery. The juvenile completed probation without incident, and the charge was dismissed. In 2023, the now twenty-two-year-old juvenile, with no other record, petitioned to expunge his record under a statute allowing expungement if the offense is no longer a crime.The Juvenile Court denied the expungement petition. The court found that the offenses of rape of a child by force and assault and battery remain criminal acts, regardless of the age of the perpetrator, and thus do not qualify for expungement under the statute. The court also noted that the juvenile's records were ineligible for time-based expungement due to the serious nature of the offenses.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the Juvenile Court's decision. The court held that the 2018 legislative change, which excluded children under twelve from the Juvenile Court's jurisdiction, did not alter the definition of what constitutes a "crime" for the purposes of expungement under the statute. The court concluded that the relevant inquiry is whether the conduct itself has been decriminalized, not whether the individual can be prosecuted due to age. Since the conduct in question remains criminal, the juvenile's records do not qualify for expungement. View "Commonwealth v. Ambrose A." on Justia Law

The defendant, Tyrone Strong, and three accomplices planned to rob a known drug dealer, Christian Perez, at gunpoint. During the robbery in Fitchburg, Perez was fatally shot. Two accomplices were acquitted in separate trials, and a third had his indictment dismissed. Despite largely circumstantial evidence, a jury found Strong guilty of first-degree murder based on joint venture in a felony-murder with armed robbery as the predicate felony.Following his conviction, Strong filed a motion for a new trial, arguing ineffective assistance of counsel, the "rule of consistency" due to the acquittals and dismissal of his accomplices, and improper jury instructions referencing the dismissed accomplice. The motion judge, not the trial judge, denied the motion.The Supreme Judicial Court of Massachusetts reviewed the case. The court found sufficient evidence to support the conviction, including Strong's presence at the scene, the matching footwear impressions, and items belonging to the victim found in the car Strong was in. The court also found no abuse of discretion in denying the motion for a new trial, as trial counsel's strategy was not manifestly unreasonable. The "rule of consistency" did not apply because joint venture does not require a combination of individuals, and the accomplices were tried separately. The jury instructions were appropriate given the evidence suggesting the dismissed accomplice's involvement.The court affirmed Strong's conviction and the denial of his motion for a new trial, finding no reason to exercise its extraordinary power to vacate the conviction or reduce the verdict. View "Commonwealth v. Strong" on Justia Law

In 2018, the victim ended a five-year relationship with the defendant, who continued to send her text messages and occasionally parked near her home despite her efforts to avoid him. Two years later, the defendant sent the victim two text messages expressing anger and hurt. The next day, after an encounter at a fundraiser, the defendant sent another text message threatening to punch the victim.The defendant was convicted of violating the threatening to commit a crime statute in the New Bedford Division of the District Court Department. The Appeals Court affirmed the conviction, but the Supreme Judicial Court granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the jury was not instructed to find that the defendant acted with the required mens rea, as established by the U.S. Supreme Court in Counterman v. Colorado. The Court held that the conviction violated the First Amendment because the jury was not instructed to find that the defendant consciously disregarded a substantial risk that his communication would be viewed as threatening violence. The Court also concluded that the threatening to commit a crime statute is not facially overbroad when construed to require proof of recklessness. The Court vacated the defendant's conviction and remanded the case for a new trial, allowing the Commonwealth to retry the defendant with proper jury instructions. View "Commonwealth v. Cruz" on Justia Law

In 1999, the defendant admitted to sufficient facts to support a finding of guilty for distributing a class A substance. He later sought to withdraw this admission, claiming his plea counsel failed to inform him that it would lead to mandatory deportation. The defendant, a legal permanent resident since 1994, argued that he would have insisted on going to trial had he known the immigration consequences, citing his strong ties to the United States, including his American citizen wife and children, and his consistent employment as a welder.The defendant's initial motion for a new trial was denied due to the absence of an affidavit from his plea counsel. He then filed a renewed motion with the necessary affidavit, which was also denied by a District Court judge after a non-evidentiary hearing. The judge concluded that while the plea counsel was ineffective, the defendant failed to demonstrate prejudice. The Appeals Court affirmed this decision.The Supreme Judicial Court of Massachusetts reviewed the case, focusing on whether the defendant established prejudice from his counsel's ineffectiveness. The court found that the motion judge improperly assessed the defendant's claim by not applying the reasonable person standard and by making credibility determinations about the defendant's assertion that he would have gone to trial. The court vacated the denial of the renewed motion and remanded the case for further findings on whether the defendant's ties to the United States constituted special circumstances and whether a reasonable person in his situation would have chosen to go to trial if properly advised. View "Commonwealth v. Torres" on Justia Law

An undercover police officer, without a warrant, used his cell phone to make audio-visual recordings while purchasing drugs from the defendant. These recordings captured both the audio of their conversations and video footage of the defendant. The defendant was subsequently charged with multiple counts of drug distribution and moved to suppress the recordings, arguing they were unlawful interceptions under the wiretap act.The Superior Court judge partially granted the motion, suppressing the audio but allowing the video footage to be used as evidence if shown silently. Both parties sought interlocutory appeal. The Appeals Court ruled that both the audio and video components must be suppressed under the wiretap act. The Commonwealth then sought further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and held that the wiretap act's suppression remedy extends to both the audio and video components of the recordings. The court reasoned that the video footage, even without audio, contains information about the identity of the parties and the existence of the communication, which falls under the statute's definition of "contents." Therefore, the entire recording must be suppressed to align with the legislative intent of protecting privacy and deterring unauthorized surveillance.The court affirmed the suppression of the audio and reversed the decision allowing the video footage, ordering that both components be suppressed. View "Commonwealth v. Du" on Justia Law

On August 14, 2018, Yashua Amado, Darrell Smith, and Jerome Smith were shot while sitting in Amado's car on Deering Road in Mattapan. Amado was killed, and Darrell and Jerome sustained non-life-threatening injuries. The shooter was never identified. Dewane M. Tse was indicted for first-degree murder and two counts of armed assault with intent to murder, accused of participating in a joint venture by following the victims and driving the shooter to and from the crime scene.In the Superior Court, a jury convicted Tse of first-degree murder based on deliberate premeditation regarding Amado and armed assault with intent to murder Darrell. Tse was acquitted of the charge related to Jerome. Tse's motions for required findings of not guilty were denied by the trial judge, who sentenced him to life without parole for the murder and a concurrent term for the assault. Tse appealed, arguing insufficient evidence to prove he knowingly participated in the shooting or shared the shooter's lethal intent.The Supreme Judicial Court of Massachusetts reviewed the case. The court found insufficient evidence to prove beyond a reasonable doubt that Tse knew of or shared the shooter's lethal intent. The court noted that the evidence, including GPS data, cell site location information, and video footage, did not establish Tse's knowledge or intent to kill. The court emphasized that the Commonwealth's argument relied on speculative assertions about Tse's maneuvering of the vehicle, which was insufficient to prove shared lethal intent.The court reversed Tse's convictions for first-degree murder and armed assault with intent to murder, set aside the verdicts, and remanded the case to the Superior Court for entry of required findings of not guilty. View "Commonwealth v. Tse" on Justia Law

A juvenile was seen masturbating in a parked car and was charged with open and gross lewdness and lascivious behavior, a felony. At trial, the jury was also instructed on the lesser included offense of indecent exposure, a misdemeanor punishable by no more than six months in jail. The jury found the juvenile delinquent only of the lesser included offense. The juvenile, who had no prior offenses, argued that the delinquency adjudication must be dismissed for lack of subject matter jurisdiction.The Juvenile Court judge denied the motion to dismiss and sentenced the juvenile to a continuance without a finding until his nineteenth birthday, after which the charge was dismissed. The juvenile appealed, and the Supreme Judicial Court transferred the case from the Appeals Court to address whether the Juvenile Court retained jurisdiction over a first offense of a minor misdemeanor after a jury trial.The Supreme Judicial Court concluded that once the jury found the juvenile delinquent only of a minor misdemeanor and it was undisputed that it was his first offense, the Juvenile Court no longer had subject matter jurisdiction. The court held that the delinquency adjudication should have been dismissed and recorded only as a Wallace W. determination. The court vacated the adjudication of delinquency and remanded the matter to the Juvenile Court with instructions to make the appropriate entry. View "Commonwealth v. Vince V." on Justia Law

The case involves a dispute over the interpretation of a statutory provision requiring the Executive Office of Housing and Livable Communities (HLC) to provide immediate temporary emergency shelter to families who appear to be eligible based on their statements and information already in the agency's possession. The plaintiffs, representing a class of individuals, argued that HLC's requirement for third-party verification of identity, familial relationship, and Massachusetts residency at the time of initial application for emergency assistance shelter was contrary to the statutory language.The Superior Court judge ruled that HLC could not require third-party verification of Massachusetts residency but could require verification of family status and identity, except for pregnant women. Both parties appealed this decision.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the plain language of the statutory provision did not permit HLC to require third-party verification at the time of initial application. The court emphasized that the statute mandates immediate provision of shelter based on the family's statements and information in HLC's possession, without delay. The court found that the requirement for third-party verification at the initial application stage would contradict the statute's intent to provide immediate temporary shelter to those in need.The Supreme Judicial Court reversed the Superior Court's judgment to the extent it allowed HLC to require third-party verifications before providing shelter under the immediate placement proviso. The judgment was otherwise affirmed. View "Garcia v. Executive Office of Housing and Livable Communities" on Justia Law