Justia Massachusetts Supreme Court Opinion Summaries

The mayor of a city in Massachusetts decided to commission and install two ten-foot-tall bronze statues of Saint Michael and Saint Florian on the façade of a new public safety building, using public funds. Both figures are Catholic saints, recognized for their religious significance and as patron symbols of police and firefighters. The statues were to be the only adornments on the building, which serves various public functions and is located on a prominent city street. The city had already spent over $760,000 on the statues, with additional costs anticipated for their installation. News of the statues’ religious symbolism led to significant public opposition, including protests, petitions, and statements from local faith leaders expressing concern about the exclusionary message conveyed by featuring only Catholic figures on a municipal building.Fifteen city residents and taxpayers filed suit in Norfolk County Superior Court against the city and the mayor in his official capacity. They sought to enjoin further expenditure of public funds and prohibit installation of the statues, arguing that the actions violated Article 3 of the Massachusetts Declaration of Rights, as amended, which bars the establishment or subordination of any religious sect. The Superior Court judge granted a preliminary injunction stopping further installation and denied the city’s motion to dismiss, finding the plaintiffs had standing as taxpayers and had shown a likelihood of success under the standard set in *Colo v. Treasurer & Receiver General*.On direct appellate review, the Supreme Judicial Court of Massachusetts affirmed the Superior Court’s orders. The Court held that the plaintiffs had standing under the ten-taxpayer statute and that the constitutionality of the statues must be analyzed under the framework set out in *Colo*, which emphasizes constitutional text, history, purpose, and factors such as secular purpose, primary effect, and potential for divisiveness. The Court concluded that the statues likely violated Article 3 by conveying government endorsement of a particular religion, and that the public interest favored an injunction. The orders granting the preliminary injunction and denying the motion to dismiss were affirmed. View "Fitzmaurice v. City of Quincy" on Justia Law

A nonprofit organization and several individuals, most residing near Franklin Park in Boston, challenged the city’s decision to enter into agreements allowing a private company to demolish and reconstruct White Stadium and to lease a portion of the new stadium for use as a professional women’s soccer venue. The plaintiffs argued that the land in question, originally acquired as parkland, remained subject to Article 97 of the Amendments to the Massachusetts Constitution, which requires a two-thirds legislative vote to dispose of or change the use of protected parkland. They also claimed that the agreements breached the terms of a public charitable trust, the George Robert White Fund, from which the stadium parcel was transferred, and that the city failed to meet other statutory requirements.The Superior Court dismissed the plaintiffs’ trust-based claims for lack of standing, finding that only the Attorney General or trustees can enforce a public charitable trust unless an individual plaintiff can show a distinct personal interest. After a bench trial, the court ruled in favor of the defendants on the remaining claims, concluding that the stadium parcel was no longer protected parkland at the time of the agreements and that the plaintiffs had not demonstrated violations regarding areas outside the stadium parcel.On appeal, the Supreme Judicial Court of Massachusetts affirmed. The court held that the plaintiffs lacked standing to enforce the White Fund’s trust terms. It further determined that, due to legislative actions in 1947 and 1950, the stadium parcel was removed from its park designation and dedicated as a school facility, so Article 97’s protections did not apply. The court also found that the agreements did not grant an easement over other areas of Franklin Park and that planned improvements outside the stadium parcel did not alter their park use. The judgment for the defendants was affirmed. View "Emerald Necklace Conservancy, Inc. v. City of Boston" on Justia Law

An individual was accused by his stepdaughter of multiple incidents of sexual abuse when she was eleven years old. He denied these allegations, but in 2017, a jury convicted him of two counts of indecent assault and battery on a child under fourteen. These convictions required him to register as a sex offender. Over the next several years, the relevant state board classified him multiple times as a level two sex offender, with each classification subject to objections, appeals, or procedural errors that resulted in vacatur or amendment. In his most recent classification proceeding, he requested funds for an expert to testify about the relationship between repetitive sexual offenses and dangerousness, particularly whether current research supported using multiple offenses as a factor in assessing his future dangerousness. The hearing examiner denied this request, finding the proposed testimony would not be unique to his case. The examiner then found by clear and convincing evidence that he posed a moderate risk of reoffense and dangerousness, ordering registration as a level two offender.He sought judicial review in the Massachusetts Superior Court, which affirmed both the substantive classification decision and the denial of expert funds. He timely appealed, and the Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the denial of funds for expert testimony was an abuse of discretion. The court found that the request for expert funds was sufficiently specific and relevant to the novel application of a regulatory factor assessing dangerousness based on multiple offenses, especially given recent changes in the application of similar factors and the lack of clear empirical support. The court vacated the Superior Court judgment and remanded the matter to the board for further proceedings, including granting the request for expert funds. View "Doe v. Sex Offender Registry Board" on Justia Law

In October 2021, while working on a roofing project at a resort in Hancock, the plaintiff, an employee of a subcontractor, fell from the roof and sustained severe injuries. The plaintiff’s employer, MBT Construction Corp., had been subcontracted by the defendant, a general contractor, to carry out the roof replacement. The subcontract did not specify which party was responsible for jobsite safety, provision of safety equipment, or worker training. On the day of the incident, the plaintiff detached his safety harness to move shingles and fell before reattaching to another safety line. MBT had previously received citations from OSHA for safety violations, but both MBT and the defendant had a longstanding business relationship.The plaintiff filed a negligence and negligent hiring suit against the defendant in the Superior Court, arguing that the defendant failed to supervise and enforce safety protocols and had hired MBT despite knowledge of its inadequate safety history. The defendant moved for summary judgment, asserting it did not owe a duty of care to the plaintiff and that state law did not recognize a negligent hiring claim in these circumstances. The Superior Court judge agreed, finding that the defendant lacked control over MBT’s work and that the plaintiff, as the subcontractor’s employee, could not bring a negligent hiring claim against the general contractor.The Supreme Judicial Court of Massachusetts reviewed the case upon transfer. It affirmed summary judgment for the defendant, holding that the general contractor did not owe a duty of care to the plaintiff because it did not retain or exercise control over the injury-producing safety measures. The Court also held that Massachusetts law does not recognize an independent negligent hiring duty owed by a general contractor to a subcontractor’s employee for injuries arising from the subcontractor’s work under these facts. The judgment for the defendant was affirmed. View "Suquilanda v. Skyway Roofing, Inc." on Justia Law

The case concerns a fatal stabbing that occurred outside a shelter where both the defendant and the victim resided. On the night of the incident, the defendant reported to shelter staff that the victim was intoxicated and behaving aggressively. After this report, both men left the shelter and walked toward the street, with shelter staff anticipating a potential fight due to shelter rules against fighting on the premises. Surveillance footage captured part of the altercation in which the defendant stabbed the victim multiple times, resulting in the victim’s death. The defendant claimed self-defense, arguing that the victim was the first to use deadly force by attacking him with a screwdriver.The case was tried in the Massachusetts Superior Court, where the defendant was convicted by a jury of murder in the first degree on a theory of deliberate premeditation. The defense requested, but later withdrew, an instruction on voluntary manslaughter by sudden combat. After his conviction, the defendant filed a motion for a new trial, arguing that his counsel was ineffective for not introducing evidence of the victim’s prior violent conduct under Commonwealth v. Adjutant, and that the trial judge should have instructed the jury on voluntary manslaughter by sudden combat. The motion was denied by a different Superior Court judge, who found counsel’s decision strategic and not manifestly unreasonable.The Supreme Judicial Court of Massachusetts reviewed both the direct appeal and the denial of the motion for a new trial. It held that trial counsel’s decision not to introduce evidence of the victim’s prior bad acts was not manifestly unreasonable, as its probative value was limited and it would have allowed the Commonwealth to introduce the defendant’s own violent history. The Court also found that the evidence did not warrant a sudden combat manslaughter instruction. The Supreme Judicial Court affirmed the conviction and the denial of the motion for a new trial. View "Commonwealth v. Ramos" on Justia Law

Two separate criminal cases involved the seizure of cell phones from defendants following their arrests for offenses involving the sexual exploitation of minors. In one case, police responded to a 911 call in which a child reported repeated sexual assaults by a convenience store clerk, who had allegedly photographed the victim’s genitals. The suspect was arrested and his cell phone was seized as potential evidence. In the other case, a foster parent was accused by two children of repeated sexual abuse, including using his cell phone to photograph and display sexually explicit images. He was arrested after being contacted on the same cell phone, which was then seized.In both cases, the Commonwealth delayed seeking warrants to search the seized phones—109 days in the first case and 123 days in the second—citing investigative workloads and the time required to complete lengthy affidavits. The Superior Court in each instance allowed the defendants’ motions to suppress the evidence obtained from the phones, finding that the delays rendered the continued seizures unreasonable under Massachusetts law, relying on Commonwealth v. White, which had found a 68-day delay unreasonable under its facts. The Commonwealth sought interlocutory review. In the Diaz case, the Appeals Court affirmed suppression, and the Supreme Judicial Court of Massachusetts granted further appellate review. Both cases were ultimately reviewed together by the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court of Massachusetts held that, under the totality of the circumstances, the delays did not make the continued seizures unreasonable. The Court emphasized that when police have probable cause and the device is itself evidence of the crime, the government’s interest in retaining the phone may outweigh the defendant’s possessory interest, especially if the defendant does not seek return of the phone and there is no evidence of particular hardship. The orders suppressing the evidence were reversed and the cases remanded. View "Commonwealth v. Solis" on Justia Law

Police officers in Boston were investigating a recent robbery and shooting at an apartment complex. The victim described the suspect as a tall man in black clothing with a camouflage mask and a southern accent. Surveillance footage from the complex showed an individual whose clothing and appearance matched this description, including a distinctive hat, jacket, and sneakers. Additional footage the next day showed the same individual without a mask, reinforcing the identification. Twelve days later, a housing authority officer monitoring live surveillance spotted a person matching the suspect’s description, and police responded to the location.A Suffolk County grand jury indicted the defendant for armed robbery and drug offenses. The defendant moved to suppress evidence—money and drugs—that he discarded while fleeing from police, arguing that his seizure was not supported by reasonable suspicion. The Superior Court judge denied the motion, finding reasonable suspicion existed once the defendant was apprehended after his flight. At trial, the Commonwealth did not proceed on the robbery charge, and a jury convicted the defendant of possession with intent to distribute a controlled substance.The Appeals Court affirmed the conviction, concluding that reasonable suspicion justified the seizure. On further appellate review, the Supreme Judicial Court of Massachusetts held that the defendant was seized when police from multiple directions began to pursue him in response to his flight, which occurred before he abandoned the drugs. The court concluded that, at that moment, the officers had reasonable suspicion, based on specific and articulable facts from the ongoing investigation and video evidence, to believe the defendant had committed the robbery. Therefore, the drugs were not the fruit of an unlawful seizure, and the denial of the motion to suppress was affirmed. View "Commonwealth v. Palmer" on Justia Law

A physician purchased a medical professional liability insurance policy that included a “limited regulatory defense” provision requiring the insurer to cover defense costs for administrative proceedings related to patient complaints about the physician’s professional activities. During the policy period, the husband of a former patient filed a complaint with the Board of Registration in Medicine, alleging both the physician’s criminal conduct unrelated to medical care and an allegation that the physician prescribed an addictive medication to the patient when her primary care physician would not, due to concerns about addiction.The insurer denied coverage for defense costs in the administrative proceedings, arguing that the proceeding did not arise from a “covered claim” or a patient complaint about the physician’s “professional activities” as required by the policy. The insurer maintained that the criminal conduct alleged was not related to the provision of professional medical services. In Superior Court, following a jury-waived trial on agreed facts, the judge sided with the insurer, concluding that the allegations did not arise from the physician’s professional services, but instead from unrelated criminal conduct, and entered judgment for the insurer.The Supreme Judicial Court of Massachusetts reviewed the case de novo. It held that, although most of the alleged criminal conduct was not covered as professional services, the allegation regarding prescribing an addictive medication when the patient’s primary care physician refused did constitute a “professional service” under the policy. The Court reasoned that prescribing medication is a professional act requiring specialized medical knowledge, and the allegations created at least a possibility of coverage. Because one covered allegation triggers the duty to defend all claims in the proceeding, the Court vacated the Superior Court order and remanded for further proceedings. View "O'Connor v. MAG Mutual Insurance Company" on Justia Law

The case involves a woman who stabbed her two young sons to death in February 2018. Prior to the murders, she had been perceived as a caring mother with no documented mental illness, but she became obsessed with conspiracy theories, particularly the Illuminati, and exhibited increasingly paranoid behavior. After the killings, she provided conflicting accounts to police, alternately blaming others and describing ritualistic motives related to her delusions. Evidence at trial included her statements, the crime scene, and her behavior before and after the murders.The defendant was indicted in the Superior Court on two counts of first-degree murder and one count of willfully misleading police officers. She filed notice of intent to rely on a defense of lack of criminal responsibility. At trial, her expert witness examined her medical records from MCI-Framingham and WRCH, which documented her mental health treatment and diagnoses post-arrest. The trial judge excluded these medical records from evidence, applying a common-law evidentiary rule about expert testimony and determining they could only be referenced if the Commonwealth opened the door during cross-examination. The jury convicted her on both murder counts.On appeal to the Supreme Judicial Court of Massachusetts, the defendant argued that exclusion of her medical records impeded her criminal responsibility defense and that the prosecutor’s closing argument was improper. The Supreme Judicial Court held that the trial judge erred in excluding the medical records, which were admissible under G. L. c. 233, § 79, and that this exclusion constituted prejudicial error. The Court vacated the convictions, set aside the verdicts, and remanded the case for a new trial. The Court also addressed issues regarding the prosecutor’s closing argument for guidance on retrial. View "Commonwealth v. Sanders" on Justia Law

The defendant was convicted by a jury of murder in the first degree, resisting arrest, and possession of a class B substance after fatally stabbing his live-in girlfriend in their apartment. The incident occurred after a dispute, and the victim was found dead in the building’s entryway. The scene contained significant blood evidence, and the defendant was found in the apartment with both himself and the couch covered in blood. At trial, the defendant admitted to killing the victim but claimed he acted in self-defense while under the influence of PCP, arguing he only used excessive force and lacked premeditated intent. The medical examiner determined the victim suffered multiple sharp-force injuries, some consistent with defensive wounds.Following a mistrial in 2020 due to the COVID-19 pandemic, a second trial in 2021 resulted in the defendant’s conviction in the Hampden Superior Court. The court sentenced him to life imprisonment without parole for murder and concurrent sentences for the other offenses. The defendant later moved for a new trial, arguing ineffective assistance of counsel based on four grounds: failure to investigate his PTSD, failure to investigate the victim’s violent history, failure to introduce evidence of the victim’s recent drug use, and failure to introduce expert testimony corroborating his defensive injury. The motion was denied after a nonevidentiary hearing.The Supreme Judicial Court of Massachusetts reviewed both the direct appeal and the denial of the motion for a new trial. The court held that there was no reversible error and that counsel’s performance did not create a substantial likelihood of a miscarriage of justice. The court also declined to reduce the murder conviction to a lesser degree under G. L. c. 278, § 33E. The convictions and the denial of a new trial were affirmed. View "Commonwealth v. Dorsey" on Justia Law