Justia Massachusetts Supreme Court Opinion Summaries

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A general contractor, Graycor Construction Company Inc., was involved in a dispute with a subcontractor, Business Interiors Floor Covering Business Trust, over unpaid invoices for flooring work performed on a movie theater project. Business Interiors submitted three separate applications for periodic payments, which Graycor neither approved nor rejected within the time limit set by the Prompt Pay Act. As a result, the applications were deemed approved under the Act. Business Interiors sued Graycor for breach of contract and other claims in the Superior Court. The Superior Court granted Business Interiors's motion for summary judgment on its breach of contract claim and entered separate and final judgment. Graycor appealed.Graycor argued that the original contract was not a "contract for construction" within the meaning of the Act, and that it had a valid impossibility defense due to its failure to pay. The Supreme Judicial Court held that the Act defines its scope broadly, and the subcontract at issue was a "contract for construction" under the Act. The Court also held that common-law defenses are not precluded by the Act, but a contractor that does not approve or reject an application for payment in compliance with the Act must pay the amount due prior to, or contemporaneous with, the invocation of any common-law defenses in any subsequent proceeding regarding enforcement of the invoices. As Graycor sought to exercise its defenses without ever paying the invoices, it could not pursue the defenses. The Court also vacated and remanded the rule 54 (b) certification to the motion judge for reconsideration. View "Business Interiors Floor Covering Business Trust v. Graycor Construction Company Inc." on Justia Law

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The case involves a dispute over the eligibility of a married individual, Costa Tingos, for Medicaid long-term care benefits. Costa and his wife, Mary, had been married for over 50 years, but had kept their finances largely separate due to Costa's history of gambling and financial mismanagement. When Costa moved into a nursing home, he applied for Medicaid benefits. However, Mary refused to provide information about her income and assets, which was necessary to determine Costa's eligibility. Costa argued that Mary's refusal to cooperate should not affect his eligibility.The case was initially heard by the Massachusetts Medicaid program, MassHealth, which denied Costa's application. Costa appealed to the MassHealth board of hearings, which also denied his appeal. Costa then sought judicial review in the Superior Court, which vacated the board's decision and remanded the case back to the board. After two more rounds of hearings and appeals, the Superior Court affirmed the board's decision to deny Costa's application.The Supreme Judicial Court of Massachusetts affirmed the decision of the Superior Court. The court held that the board's interpretation of the phrase "refuses to cooperate" in the relevant regulation was reasonable. The court found that Mary's refusal to disclose her financial information did not constitute a refusal to cooperate within the meaning of the regulation, given the couple's long history of cooperation in other aspects of their marriage. The court also rejected Costa's argument that the board's decision was arbitrary and capricious. View "Freiner v. Secretary of the Executive Office of Health and Human Services" on Justia Law

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A group of Massachusetts registered voters challenged the Attorney General's certification of Initiative Petition 23-12, which proposed "a Law Requiring the Full Minimum Wage for Tipped Workers with Tips on Top." The plaintiffs argued that the petition violated the requirement under art. 48 of the Amendments to the Massachusetts Constitution that initiative petitions contain only related or mutually dependent subjects. The petition proposed two changes: first, it would require employers to pay the full minimum wage to tipped employees, and second, it would permit tip pooling among both tipped and non-tipped employees.The plaintiffs commenced this action in the county court, claiming that the Attorney General's certification of the petition was in error because the petition did not contain only related or mutually dependent subjects. The single justice reserved and reported the case to the full court.The Supreme Judicial Court for the county of Suffolk affirmed the Attorney General's certification of the petition as in proper form to be submitted to voters. The court concluded that the petition, which would require that employers pay the full minimum wage to tipped employees and would permit tip pooling among both tipped and non-tipped employees, forms a "unified statement of public policy on which the voters can fairly vote 'yes' or 'no.'" The court found that the two provisions of the petition were closely related and shared a well-defined common purpose related to ending the existing compensation system common to tipped industries. View "Clark v. Attorney General" on Justia Law

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The case involves a defendant, Nelson Barros, who was charged with assault and battery on a household member. Barros, a noncitizen, chose to represent himself during his arraignment and plea hearing. He signed a form acknowledging he had waived his right to counsel. The judge did not conduct any further inquiry to determine whether Barros' waiver of counsel was made knowingly and intelligently. Barros later admitted to sufficient facts to warrant a guilty verdict and was placed on probation for one year. After completing his probation, the charge was dismissed. However, upon returning to the U.S. from a trip to Portugal, Barros was detained by Immigration and Customs Enforcement officers due to his admission of guilt in the assault case.The lower courts denied Barros' motions to withdraw his plea. The motion judge found that Barros' waiver of the right to counsel was knowing and voluntary. Barros appealed, and the Supreme Judicial Court granted his application for direct appellate review.The Supreme Judicial Court of Massachusetts held that a defendant's waiver of the right to counsel must be made knowingly and intelligently, regardless of whether the defendant is at arraignment or a plea hearing. The court confirmed that a trial court judge has the responsibility of ascertaining whether the waiver is made knowingly and intelligently. The court also recognized that for a noncitizen defendant, the disadvantages of self-representation include forgoing counsel's advice about the immigration consequences of a disposition. However, the court affirmed the lower court's decision on alternate grounds, concluding that Barros' waiver of counsel was invalid, but he failed to establish a substantial risk of a miscarriage of justice to prevail on appeal. View "Commonwealth v. Barros" on Justia Law

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The case involves a dispute between William Good and Uber Technologies, Inc., and Rasier, LLC (collectively, Uber), and one of its drivers, Jonas Yohou. Good, a chef, used Uber's mobile application to secure a ride. On April 25, 2021, when Good opened Uber's app, he was presented with a screen notifying him of Uber's updated terms of use. The screen required Good to check a box indicating that he had reviewed and agreed to the terms before he could continue using the app. Five days later, Good used Uber's app to order a ride home from work. During the ride, Yohou's car collided with another vehicle, causing Good to suffer severe injuries.Good filed a negligence lawsuit against Uber and Yohou in the Superior Court Department. The defendants filed a motion to compel arbitration based on the terms of use that Good had agreed to. The motion judge denied the motion, finding that a contract had not been formed because Good neither had reasonable notice of Uber's terms of use nor had manifested assent to the terms.The Supreme Judicial Court of Massachusetts reversed the lower court's decision. The court found that Uber's "clickwrap" contract formation process provided Good with reasonable notice of Uber's terms of use, including the agreement to arbitrate disputes. The court also found that Good's selection of the checkbox and his activation of the "Confirm" button reasonably manifested his assent to the terms. The court remanded the case for entry of an order to submit the claims to arbitration. View "Good v. Uber Technologies, Inc." on Justia Law

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The case involves Edward A. Cianci and Raymond Frechette, who purchased a foreclosed property and initiated a summary process action in the Housing Court against the occupants, including Elizabeth D'Andrea. The Housing Court ruled in favor of the plaintiffs for possession. D'Andrea appealed and sought to waive the appeal bond due to her indigency. The Housing Court found D'Andrea to be indigent and waived her appeal bond, but required her to make monthly use and occupancy payments of $1,275 to the plaintiffs to maintain her appeal. D'Andrea appealed this order to the Appeals Court, which reported questions of law to the Supreme Judicial Court.The Supreme Judicial Court of Massachusetts held that use and occupancy payments required of an indigent party under G. L. c. 239, § 5 (e), may not be waived, substituted, or paid by the Commonwealth under the indigency statute because use and occupancy payments are not an "extra fee or cost" as defined in the indigency statute. The court further concluded that the order setting use and occupancy payments in this case did not violate D'Andrea's constitutional rights, even if the order requires her to make payments that potentially exceed her ability to pay. The court reasoned that the summary process statute reasonably imposes a fair balancing of interests between the owner of the property and the party in possession, and the Housing Court performed the fair balancing required. View "Frechette v. D'Andrea" on Justia Law

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The case involves a dispute between William Good and Uber Technologies, Inc., and Rasier, LLC (collectively, Uber). Good, a user of Uber's ride-hailing service, suffered severe injuries in a car accident while riding in a vehicle driven by an Uber driver. He filed a negligence lawsuit against Uber and the driver. Uber moved to compel arbitration based on its terms of use, which Good had agreed to when he used the Uber app.The Superior Court denied Uber's motion to compel arbitration. The court found that Uber had not provided Good with reasonable notice of its terms of use, and that Good had not reasonably manifested his assent to those terms.The Supreme Judicial Court of Massachusetts reversed the lower court's decision. The court found that Uber's "clickwrap" contract formation process, which required Good to click a checkbox indicating that he had reviewed and agreed to the terms and then to activate a button labeled "Confirm," put Good on reasonable notice of Uber's terms of use. The court also found that Good's selection of the checkbox and his activation of the "Confirm" button reasonably manifested his assent to the terms. Therefore, the court concluded that a contract had been formed between Good and Uber, and that the dispute should be submitted to arbitration as per the terms of that contract. The case was remanded for entry of an order to submit the claims to arbitration. View "Good v. Uber Technologies, Inc." on Justia Law

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The case revolves around a defendant, Nelson Barros, who was charged with one count of assault and battery on a household member. Barros, a noncitizen, chose to represent himself during his arraignment and plea hearing. He signed a form acknowledging he had waived his right to counsel. The judge informed him of his right to counsel and confirmed that Barros wished to represent himself. However, the judge did not conduct any further inquiry to determine whether Barros' waiver of counsel was made knowingly and intelligently. Barros admitted to sufficient facts to warrant finding him guilty and was placed on one year of probation. Later, Barros was detained by Immigration and Customs Enforcement officers due to his admission to sufficient facts to find him guilty of assault and battery on a household member.The lower courts denied Barros' motions to withdraw his plea. The motion judge, who was not the plea judge, found that Barros' waiver of the right to counsel was knowing and voluntary. Barros appealed, and the Supreme Judicial Court granted his application for direct appellate review.The Supreme Judicial Court of Massachusetts affirmed the lower court's decision but on alternate grounds. The court held that Barros' waiver of counsel was invalid, in violation of his right to counsel under art. 12 of the Massachusetts Declaration of Rights. The judge did not conduct an adequate inquiry to determine whether Barros' waiver of counsel was made knowingly and intelligently. However, Barros did not challenge this waiver of counsel in his first motion to withdraw his admission to sufficient facts. Therefore, he must establish a substantial risk of a miscarriage of justice to prevail on appeal. The court concluded that Barros did not raise a serious doubt that the result of the proceeding might have been different had his waiver of counsel been adequately informed. View "Commonwealth v. Barros" on Justia Law

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The case involves New England Auto Max, Inc., and others (the defendants), who are involved in a civil action where they unsuccessfully moved to dismiss the action for exceeding the $50,000 limit. The defendants then petitioned the Supreme Judicial Court for extraordinary relief, which was denied on the grounds that the defendants had an alternate avenue of appellate relief. The defendants appealed this decision.The case was initially heard in the District Court, where the defendants' motion to dismiss the action for exceeding the $50,000 limit was denied. The defendants then petitioned the Supreme Judicial Court for extraordinary relief, which was denied by a single justice on the grounds that the defendants had an alternate avenue of appellate relief. The defendants appealed this decision to the Supreme Judicial Court.The Supreme Judicial Court held that the single justice did not err or abuse his discretion in denying relief to the defendants. However, the court decided to exercise its discretion to address the question of law presented by the defendants. The court held that the defendants had a right to an interlocutory appeal to the Appellate Division of the District Court on the question of law they presented before the court. The court also concluded that the District Court judge erred in holding that the court could not look beyond a plaintiff's initial statement of damages in assessing whether there is a reasonable likelihood that recovery by the plaintiff will exceed $50,000. The case was remanded to the county court for entry of an order vacating the denial of the defendants' motion to dismiss and remanding to the District Court for further proceedings consistent with the court's opinion. View "New England Auto Max, Inc. v. Hanley" on Justia Law

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The case involves Brandyn Lepage, who was convicted of first-degree murder on the theory of felony-murder. Lepage shot and killed Aja Pascual in her car on September 29, 2012. The police obtained call logs from the victim's phone, which showed that Lepage had called the victim shortly before her death. The police also obtained Lepage's cell phone records, including call detail records, historical cell site location information (CSLI), and ping data, without a warrant. Lepage appealed his conviction and the denial of his motion for a new trial, arguing that the police illegally obtained his cell phone records.The Superior Court Department had denied Lepage's pretrial motions to suppress the cell phone records. The court found that the police did not illegally obtain Lepage's call detail records and did not use the CSLI or ping data in the manner Lepage alleged. Lepage's motion for a new trial was also denied by the same judge who had previously denied his motions to suppress.The Supreme Judicial Court affirmed Lepage's conviction of murder in the first degree and the denial of his motion for a new trial. The court concluded that Lepage did not have a reasonable expectation of privacy in his call detail records, and therefore the police did not need a warrant to obtain this information. The court also found that the police did not use Lepage's CSLI or ping data to secure evidence against him. Therefore, the court concluded that there was no violation of Lepage's constitutional rights. However, the court vacated Lepage's conviction of unlawful possession of a firearm and remanded for a new trial on that indictment. View "Commonwealth v. Lepage" on Justia Law