Justia Massachusetts Supreme Court Opinion Summaries

A Massachusetts resident, Barbara, began smoking Marlboro and Parliament cigarettes manufactured by Philip Morris as a teenager and continued for decades, becoming addicted and unable to quit despite many attempts. In 2015, after finally quitting, she was diagnosed with inoperable lung cancer and died two years later. Her husband and two children, individually and on behalf of her estate, sued Philip Morris for wrongful death, alleging breach of the implied warranty of merchantability, negligent design and marketing, fraud, civil conspiracy, and deceptive trade practices.The Superior Court (trial court) dismissed claims against other defendants and tried the remaining claims against Philip Morris before a jury. The jury found for the plaintiffs on most claims, awarding $8.014 million in compensatory damages and $1 billion in punitive damages. The judge, after post-trial motions, reduced (remitted) the punitive damages to about $56 million—seven times the compensatory damages—finding the original award excessive. The judge also denied Philip Morris’s motions for a new trial and for judgment notwithstanding the verdict, concluding that the jury was not swayed by passion or prejudice and that the compensatory and punitive damages were supported by the evidence.The Supreme Judicial Court of Massachusetts reviewed the case after transferring it from the Appeals Court. The court held that the trial judge did not abuse her discretion in denying a new trial or further remittitur, and that the remitted punitive damages were constitutionally permissible in light of the egregious conduct by Philip Morris. The court also rejected Philip Morris’s arguments that the trial should have been bifurcated, that a higher burden of proof was required for punitive damages, that federal preemption barred certain claims, and that evidentiary rulings were improper. The judgment and denial of post-trial motions were affirmed. View "Fontaine v. Philip Morris USA Inc." on Justia Law

Police officers in Boston, conducting surveillance as part of a drug investigation, observed an individual commit a civil traffic infraction while driving a vehicle. At the time, the officer who observed the infraction was in an unmarked vehicle and did not attempt to stop the car, citing safety concerns. The next day, the same officers resumed surveillance and, after locating the vehicle, requested a marked police cruiser to conduct a stop. During that stop, police discovered cocaine on the individual and in the vehicle. The investigation and subsequent search were not based on any new infractions or suspicious activity, but solely on the traffic violation observed the previous day.In the Superior Court Department, the defendant was indicted for trafficking cocaine. He moved to suppress the evidence obtained during the traffic stop, arguing that the twenty-four hour delay between the observed infraction and the stop rendered the seizure unreasonable under the Fourth Amendment and Article 14 of the Massachusetts Declaration of Rights. The motion judge denied the suppression motion regarding the physical evidence, finding the stop justified by the prior day’s infraction, and the defendant was convicted after a retrial.The Supreme Judicial Court of Massachusetts reviewed the case on direct appellate review. It held that, although some delay in conducting a traffic stop for safety reasons may be reasonable, the Commonwealth failed to justify the twenty-four hour delay in this case. The Court concluded that the stop violated Article 14 because the Commonwealth did not meet its burden to show the delay was reasonable under the totality of the circumstances. The Court reversed the portion of the order denying the motion to suppress, vacated the conviction, set aside the verdict, and remanded the matter to the Superior Court. View "Commonwealth v. Arias" on Justia Law

Two former tenants sued the owner and manager of a residential apartment complex, alleging that they were charged unlawful rental application fees and excessive lock change fees, in violation of the Massachusetts security deposit statute and consumer protection laws. They sought to represent a statewide class of similarly situated tenants. After contentious discovery, the Superior Court sanctioned the defendants, precluding them from contesting certain liability facts. The court granted summary judgment to the plaintiffs on the security deposit claims but denied summary judgment on the consumer protection claims. Before trial, the parties reached a proposed class action settlement that established a fund for class members, with unclaimed funds to be distributed partly to charities and partly returned to the defendants.The Superior Court, after scrutiny and required revisions, approved the settlement. The court capped the amount of unclaimed funds that could revert to the defendants and required that a portion go to designated charities. However, the Massachusetts IOLTA Committee, a nonparty potentially entitled to notice under Mass. R. Civ. P. 23(e)(3), was not notified prior to settlement approval. After final approval and claims processing, the committee received notice for the first time and objected to the final distribution of unclaimed funds, arguing that the lack of timely notice violated the rule and that final judgment should be set aside. The motion judge agreed there was a violation but declined to vacate the settlement, finding no prejudice.On direct appellate review, the Supreme Judicial Court of Massachusetts held that the IOLTA Committee had standing to appeal the denial of its procedural right to notice and an opportunity to be heard on the disposition of residual funds, but lacked standing to challenge the overall fairness or structure of the settlement. Assuming a violation of the rule occurred, the Court found no prejudice because the committee ultimately received the opportunity to be heard before judgment entered. The judgment was affirmed. View "Ortins v. Lincoln Property Company" on Justia Law

Meta Platforms, Inc. and Instagram, LLC were sued by the Commonwealth for allegedly engaging in unfair business practices by designing the Instagram platform to encourage compulsive use among children, misleading the public about the platform's safety, and creating a public nuisance through these practices. The Commonwealth argued that Meta intentionally exploited young users’ vulnerabilities through specific design features, made deceptive statements regarding safety, and failed to effectively prevent underage users from accessing the platform despite public claims to the contrary.The case originated in the Massachusetts Superior Court. There, Meta moved to dismiss the complaint, asserting that Section 230(c)(1) of the Communications Decency Act (CDA) provided them with immunity from the Commonwealth’s claims. The judge denied Meta's motion, concluding that Section 230 did not bar the claims because the alleged harms stemmed from Meta’s own conduct and speech, rather than from third-party content. Meta then sought interlocutory review, claiming an immediate right to appeal under the doctrine of present execution due to the asserted immunity from suit.The Supreme Judicial Court of Massachusetts granted direct appellate review. The court held that the doctrine of present execution allowed an interlocutory appeal regarding Section 230 immunity because the statute confers immunity from suit, not merely from liability. On the merits, the court found that Section 230(c)(1) did not bar the Commonwealth’s claims at this preliminary stage. The court reasoned that the claims were based on Meta’s own design choices and misrepresentations, not on holding Meta liable as a publisher of third-party information. The court therefore affirmed the Superior Court’s denial of Meta’s motion to dismiss as to Section 230(c)(1). View "Commonwealth v. Meta Platforms, Inc." on Justia Law

A juvenile was charged with involuntary manslaughter and motor vehicle homicide by reckless operation following a 2019 incident at age sixteen. He pleaded guilty as a youthful offender and was sentenced under the relevant statute to a combination sentence: commitment to the Department of Youth Services (DYS) until age twenty-one, followed by a five-to-seven-year State prison sentence, suspended for five years pending successful probation. After spending approximately eighteen months in a secure DYS facility, he was released on conditional liberty. Less than two years later, he violated probation, and the previously suspended State prison sentence was imposed.The Essex County Division of the Juvenile Court Department denied his motion seeking credit toward his State prison sentence for the 549 days spent in DYS custody, which he argued constituted confinement. The judge granted him credit only for time spent in adult custody before pleading guilty and time held on the probation violation.The Supreme Judicial Court of Massachusetts reviewed the case on direct appellate review. The Court held that neither statutory law nor equitable principles entitle a juvenile in these circumstances to credit toward an adult sentence for time spent serving the DYS portion of a combination sentence. The statutes providing for jail credit apply only to time spent in custody before sentencing, not to time spent serving a sentence. The time in DYS custody was deemed part of the sentence, not “dead time.” The Court also determined that the sentencing judge lacked discretion to award such credit at the probation violation stage, and that equal protection arguments did not require a different result. Accordingly, the Supreme Judicial Court affirmed the order denying the motion for jail credit. View "Commonwealth v. Sonny S." on Justia Law

The case involves a dispute stemming from an incident where the defendant, after having moved out of the victim’s home following an altercation, unlawfully entered the victim’s residence several months later. The defendant had previously been allowed to live in the home rent-free, but was asked to leave after an argument and an arrest. On the date in question, the defendant persistently knocked on the victim’s doors before using keys, believed to have been taken from the victim’s unlocked car, to enter the locked house. Upon entry, the defendant retrieved personal items and, during an ensuing confrontation, drove off with a dog that had been given to the victim, injuring the victim in the process.The defendant was tried in the Westborough Division of the District Court Department, where she waived her right to a jury trial. The judge found her guilty of breaking and entering with intent to commit a misdemeanor, among other charges, though the Commonwealth did not specify which misdemeanor was intended. On appeal, the defendant argued there was insufficient evidence of intent to commit larceny, and the Commonwealth asserted the evidence supported intent to commit either larceny or criminal trespass. The Appeals Court found there was insufficient evidence of intent to commit larceny but affirmed the conviction based on sufficient evidence of intent to commit criminal trespass.The Supreme Judicial Court of Massachusetts reviewed the case, holding that the Commonwealth is not required to specify the intended misdemeanor at trial, and that proof of intent to commit an unspecified misdemeanor is sufficient under Massachusetts law. The court further held that, in a bench trial, the trial judge could consider any misdemeanor supported by the evidence. The court found sufficient evidence to infer intent to commit criminal trespass and affirmed the conviction. View "Commonwealth v. McGrath" on Justia Law

In this case, the defendant was charged with sexual assaults that occurred in 1993, when he was fifteen years old and the victim was nine. The assaults were not reported until 2016, when the victim, then an adult, saw the defendant and contacted the police. The defendant, who was thirty-nine years old when charged, faced both charges of rape of a child with force and statutory rape. Because the defendant was a juvenile at the time of the alleged offenses but an adult when charges were brought, a transfer hearing was held to determine whether he should be tried as an adult or discharged.A judge in the Norfolk County Division of the Juvenile Court Department conducted the transfer hearing under Massachusetts General Laws chapter 119, section 72A. The judge found probable cause that the defendant committed the offenses and, after considering arguments, decided that public interest warranted transfer to adult court. The defendant’s counsel objected, believing the hearing would be bifurcated and was unprepared to present evidence relevant to the defendant’s maturity and rehabilitation. The judge denied a continuance and ordered transfer. The defendant was indicted and convicted in the Superior Court. He later moved for a new trial, arguing ineffective assistance of counsel at the transfer hearing. The Superior Court judge denied the motion without an evidentiary hearing.The Supreme Judicial Court of Massachusetts reviewed the case and held that a section 72A transfer hearing is a critical stage of the criminal process at which a defendant is entitled to effective assistance of counsel. The Court found that the defendant was denied such assistance because his counsel was unprepared to present evidence relevant to the transfer decision. The Court vacated the order denying the motion for a new trial and remanded for a new transfer hearing, directing that the defendant’s convictions would remain provisionally in place pending the outcome of the new hearing. View "Commonwealth v. Donovan" on Justia Law

Late one evening, the defendant and two companions met with Bethgy Cator and Mayklens Francois in a Brockton parking lot for a marijuana transaction. After some negotiation, the defendant moved to Cator’s car, and the group drove off, with the defendant’s companions following in a separate vehicle. During the drive, the defendant testified that Francois pointed a gun at him and that both Cator and Francois threatened to rob him. After Cator pulled into a laundromat lot and made a sudden stop, the defendant claimed he saw Cator reaching for a gun. The defendant then drew his own gun and fired, killing Cator and injuring Francois, before fleeing the scene with his girlfriend. Ballistics evidence and surveillance video were collected; a .25 caliber firearm was recovered at the scene, but there was no evidence it was fired during the incident.At trial in the Massachusetts Superior Court, the defendant was convicted by a jury of murder in the first degree, assault with attempt to kill, and firearms offenses. The defendant argued on appeal that the trial judge mishandled the admission of hearsay statements made by Francois, the surviving victim, to police. The statements included Francois’s admission that he possessed a firearm during the confrontation and his explanation about disposing of it, which the defendant contended were central to his claim of self-defense. Initially, the judge excluded these statements as irrelevant unless the defendant testified, which led the defendant to take the stand.The Supreme Judicial Court of Massachusetts held that the trial judge erred in excluding Francois’s statements from the Commonwealth’s case-in-chief, as they were relevant to the defendant’s self-defense claim. The court found this error prejudicial, as it affected the defendant’s substantial rights and trial strategy. Consequently, the court vacated the convictions and remanded the case for a new trial, also vacating the firearms convictions in accordance with recent precedent. View "Commonwealth v. Williams" on Justia Law

This case centers on a dispute involving the planned construction of a new cottage by a hotel operator on Martha’s Vineyard. The hotel, situated in a residential area, is considered a preexisting nonconforming commercial use. In 2008, the hotel’s predecessor sought permission for expansion and entered into an agreement with a neighboring property owner, who agreed not to oppose the project or appeal permit decisions, in exchange for promises including the installation and maintenance of vegetative screening. After subsequent changes to the project—including the removal and replacement of screening and the relocation and resizing of the cottage—the neighbor, acting as trustee, objected to the most recent modifications in 2023, claiming inadequate screening and diminished privacy.Following the 2023 decision by the Edgartown zoning board of appeals approving the hotel’s modifications, the trustee filed suit challenging that decision and asserting additional claims against the hotel. The hotel counterclaimed for abuse of process, alleging that the suit was frivolous and vexatious. The Superior Court denied the trustee’s special motion to dismiss the counterclaim under the Massachusetts anti-SLAPP statute, concluding that the underlying lawsuit was a sham. The trustee appealed. The Appeals Court reversed, finding that it could not determine at that stage whether the trustee’s claims were meritless because the underlying suit was unresolved.The Supreme Judicial Court of Massachusetts held that the anti-SLAPP statute requires the party opposing dismissal to prove that the petitioning activity (the lawsuit) was devoid of reasonable factual support or any arguable basis in law. The court determined that the hotel failed to meet this burden because the trustee’s challenge to the 2023 decision was not frivolous on its face. The order denying the special motion to dismiss was therefore reversed, and the case remanded for further proceedings, including an award of attorney’s fees to the trustee. View "Allegaert v. Harbor View Hotel Owner LLC" on Justia Law

The plaintiff, a general laborer, sued his employer and its owner for violations of the Massachusetts Wage Act, alleging that he was not paid for four weeks of work. He sought damages for lost wages. The defendants denied the allegations and filed counterclaims against the plaintiff for abuse of process and malicious prosecution. In response, the plaintiff filed a special motion to dismiss the counterclaims under the Massachusetts anti-SLAPP statute, claiming the counterclaims were solely based on his act of petitioning the court to recover his wages.A judge in the Waltham Division of the District Court Department initially dismissed the counterclaims, but later reversed that decision after granting the defendants’ motion for reconsideration. The plaintiff then pursued an interlocutory appeal. The Massachusetts Appeals Court reversed the lower court’s decision and ordered the counterclaims dismissed under the anti-SLAPP statute. The Appeals Court subsequently considered the plaintiff’s unopposed petition for appellate attorney’s fees, which used the lodestar method to calculate a request of $67,361.25. Although the Appeals Court found the hours and rates reasonable, it reduced the award by half, reasoning that the fees were disproportionate to the relatively low monetary value of the underlying Wage Act claims.The Supreme Judicial Court of Massachusetts granted further appellate review, limited to the issue of appellate attorney’s fees. The court held that it was an abuse of discretion for the Appeals Court to reduce the fee award based on the value of the underlying Wage Act claims when the reasonableness of the hours and rates for the anti-SLAPP work had already been established. The Supreme Judicial Court therefore reversed the reduction and affirmed an award of $67,361.25 in appellate attorney’s fees for the anti-SLAPP work. View "Hidalgo v. Watch City Construction Corp." on Justia Law