Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the order of the trial court denying Defendant's motion for reduction of the verdict or for a new trial, holding that principles of direct estoppel precluded another review in this case.Defendant was convicted of murder in the second degree and battery by means of a dangerous weapon causing serious bodily injury. The appeals court affirmed. More than nine years after trial, Defendant filed a motion to reduce the verdict of murder in the second degree or to grant a new trial. The superior court judge concluded that principles of estoppel precluded resisting issues that substantially had been decided previously. The Supreme Judicial Court affirmed, holding that direct estoppel precluded further consideration of the issues Defendant raised on appeal. View "Commonwealth v. Arias" on Justia Law

The Supreme Judicial Court affirmed the decision of the trial court entering judgment upon the jury's verdict in this wrongful death case and awarding Plaintiff $11 million in compensatory damages and $10 million in punitive damages, holding that there was no prejudicial error.In 1995, the Attorney General filed a complaint against Philip Morris and other manufacturers of tobacco products, arguing that the companies had conspired to mislead the Commonwealth and its citizens concerning the risks of smoking. The parties settled the case three years later as part of a nationwide settlement. In 2017, Plaintiff, the widow of a smoker who died from lung cancer after decades of smoking Philip Morris cigarettes, sued Phillip Morris pursuant to the wrongful death statute, Mass. Gen. Laws ch. 229, 2. The jury rendered a verdict for Plaintiff. On appeal, Philip Morris argued that the 1998 settlement precluded Plaintiff's recovery of punitive damages. The Supreme Judicial Court affirmed, holding that the doctrine of claim preclusion did not apply in these circumstances and that Philip Morris was not prejudiced by the other asserted errors at trial. View "Laramie v. Philip Morris USA Inc." on Justia Law

The Supreme Judicial Court vacated and set aside the order of the superior court judge denying Defendant's motion to suppress the fruits of a search of Defendant's home, holding that the warrantless investigatory review of the video footage taken from use of a body-worn camera that was unrelated to the domestic disturbance call in this case was unconstitutional.As he responded to a call about a domestic disturbance at Defendant's home, a police officer, who was equipped with a body-worn camera, created a digital recording of the encounter. The video footage was later retrieved and reviewed in connection with an ongoing independent investigation of Defendant for firearms offenses. Defendant was indicted on firearms-related offenses and moved to suppress the video recording from the body-worn camera and the fruits of the search warrant. The motion judge denied the motion. The Supreme Judicial Court vacated the order denying the motion to suppress, holding that (1) the use of the body-worn camera within the home was not an unconstitutional search; but (2) the later warrantless investigatory review of the video footage violated Defendant's constitutional right to be protected from unreasonable searches. View "Commonwealth v. Yusuf" on Justia Law

The Supreme Judicial Court held that the Commissioner of Correction's exercise of the "commissioner's certification" provision in Mass. Gen. Laws ch. 18(a) to retain K.J. at Bridgewater State Hospital violated article 30 of the Massachusetts Declaration of Rights.K.J., an adult man who faced criminal charges in the district court and the superior court, was committed involuntarily to Bridgewater. The commitment was subsequently extended. This appeal concerned the medical director of Bridgewater's most recent petition to have K.J. again recommitted for one year under section 18(a). The judge found that K.J. did not require strict custody and therefore, as required by section 18(a), issued an order committing K.J. to a lower security Department of Mental Health (DMH) facility. Despite that order, the Commissioner exercised the "commissioner's certification" provision in section 18(a) to retain K.J. at Bridgewater. The Supreme Judicial Court ordered that K.J. be transferred to a DMH facility, holding (1) the commissioner's certification provision of section 18(a) violates article 30; and (2) the remainder of section 18(a) is capable of separation. View "K.J. v. Superintendent of Bridgewater State Hospital" on Justia Law

The Supreme Judicial Court held that the six-year statute of limitations for contract actions governed this case and that the efforts of Executive Office of Health and Human Services, Office of Medicaid (MassHealth) to collect overpayments made to providers in the State Medicaid program were time barred.In 2005, MassHealth sent an audit notice to a provider, Suburban Home Health Care, Inc., but took no further action until 2016, when it initiated recovery proceedings. Suburban sought declaratory relief, arguing that the proceedings were barred under the statute of limitations for "actions of contract" in Mass. Gen. Laws ch. 260, 2. The superior court denied relief, concluding that the administrative proceedings to collect the overpayments could not be considered civil actions, and therefore, no statute of limitations applied. The Supreme Judicial Court reversed, holding that the six-year statute of limitations for contract actions applied and that MassHealth's action was time barred. View "Suburban Home Health Care, Inc. v. Executive Office of Health and Human Services, Office of Medicaid" on Justia Law

The Supreme Judicial Court affirmed the order of the district court denying Defendant's motion to dismiss this personal injury action on statute of limitations grounds, holding that there was no error.Plaintiff brought this action against Defendant, a grocery store chain, alleging that she was injured in a collision with a grocery cart as a result of the negligence of one of Defendant's employees. Plaintiff filed the complaint after the expiration of the applicable period of limitation in light of the Supreme Court's order that all civil statutes of limitations were tolled from March 17, 2020 through June 30, 2020 due to the COVID-19 pandemic. The district court denied Defendant's motion to dismiss based on the plain language of the order. The Supreme Judicial Court affirmed, holding that Defendant's claims on appeal failed. View "Shaw's Supermarkets, Inc. v. Melendez" on Justia Law

The Supreme Judicial Court vacated the order of the superior court granting summary judgment in favor of Defendants and dismissing a complaint brought by the Conservation Commission of Norton, holding that the Wetlands Protection Act, Mass. Gen. Laws ch. 131, 40, did not bar this action.The Commission issued an enforcement order to owners of property on which unauthorized fill had been placed by a prior owner, ordering the current owners (Defendants) to remove the fill. The Commission brought this action seeking injunctive relief and civil penalties when Defendants failed to comply with the order. The superior court concluded that that the Act created a statute of repose that prevented the Commission from bringing the enforcement action more than three years following the first transfer of ownership in the property after the alleged violation occurred. The Supreme Judicial Court vacated the order below, holding that the Act did not bar the action because the Commission commenced this enforcement action against Defendants within three years of the recording of the deed by which they acquired title. View "Conservation Commission of Norton v. Pesa" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of armed assault with intent to rob as duplicative of his felony murder conviction and otherwise affirmed Defendant's convictions, holding that the evidence supporting the conclusion that Defendant attempted to commit an armed robbery was the same as the evidence establishing that Defendant committed an armed assault with intent to rob.After a jury trial, Defendant was convicted of murder in the first degree on the theory of felony murder, with the predicate offense of armed robbery, armed assault with intent to rob, and armed home invasion. The Supreme Judicial Court vacated Defendant's convictions of armed assault with intent to rob as duplicative of the predicate felony of armed robbery and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or reduce or set aside the verdict of murder in the first degree, holding that the conviction of armed assault with intent to rob must be vacated as duplicative of Defendant's felony-murder conviction. View "Commonwealth v. Quiles" on Justia Law

The Supreme Judicial Court held that a previously enacted municipal bylaw that permits only nonprofit entities to operate medical marijuana dispensaries is preempted by a statutory provision specifically eliminating that restriction.In 2012, marijuana was legalized for medical use, and the licensing of medical marijuana dispensaries was limited to nonprofit entities. In 2017, the marijuana laws were amended to allow for-profit entities to dispense medical marijuana. Subsequently, CommCan, Inc., a dispensary, converted from a nonprofit to a for-profit corporation. At issue was what impact the conversion had on CommCan's eligibility for a special permit previously issued by the town of Mansfield planning board. The judge found no error in the board's decision to grant CommCan a special permit and concluded that the town's bylaw requiring medical marijuana dispensaries to be operated by nonprofit entities was preempted by the 2017 act. The Supreme Judicial Court affirmed, holding that the town's bylaw was preempted by state law to the extent it required all medical marijuana dispensaries to be nonprofit organizations. View "West Street Associates LLC v. Planning Board of Mansfield" on Justia Law

The Supreme Judicial Court affirmed the judgment of the Land Court determining that, pursuant to Mass. Gen. Laws ch. 94G, 3(a)(1), the town of Mansfield may not prevent CommCan, Inc. from converting to a retail marijuana establishment, holding that there was no error.Mass. Gen. Laws ch. 94G, 3(a)(1) exempts, with some exceptions, medical marijuana dispensaries from zoning ordinances that would prohibit them from converting to retail marijuana sales. Plaintiff, the president of CommCan, received authorization from the town to construct a building that would house a medical marijuana dispensary. Before construction began, chapter 94G legalized the sale of recreation marijuana. Plaintiff sought a determination that, pursuant to section 3(a)(1), the town may not prevent CommCan from converting to a retail marijuana establishment. The Supreme Judicial Court granted summary judgment for Plaintiff. The Supreme Judicial Court affirmed, holding that the town's arguments on appeal lacked merit. View "CommCan, Inc. v. Mansfield" on Justia Law