Justia Massachusetts Supreme Court Opinion Summaries

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The Supreme Judicial Court vacated the trial judge's order allowing Defendant's motion to suppress evidence found on Defendant's cell phone and remanded the case to the superior court for further rulings regarding partial suppression, holding that there was probable cause to search Defendant's cell phone and that the search of the phone was not sufficiently particular because it lacked any temporal limit.When Defendant was arrested in connection with a fatal shooting police officers obtained a warrant to search Defendant's cell phone for evidence related to the crime. The judge allowed Defendant's motion to suppress the cell phone evidence, ruling that the warrant had issued without probable cause because it lacked a sufficient nexus between the murder and Defendant's cell phone and noting that the search was not limited in time. The Supreme Judicial Court vacated the suppression order, holding (1) there was probable cause to search Defendant's cell phone; and (2) because the record was silent with respect to the dates of the Commonwealth's proposed evidence, remand was required for a determination of whether the evidence would have fallen within a reasonable temporal limit. View "Commonwealth v. Snow" on Justia Law

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The Supreme Judicial Court held that this action against Uber Technologies, Inc. and Easier, LLC (collectively, Uber) was not arbitrable because there was no enforceable agreement between Uber and Plaintiffs.Plaintiffs brought this action under Mass. Gen. Laws ch. 272, 98A claiming that three Uber drivers refused to provide one plaintiff with rides because he was blind and accompanied by a guide dog. Citing a provision in Uber's cellular telephone application, which Plaintiffs had used to register with Uber, Uber moved to compel arbitration. The judge granted the motion. The arbitrator ruled in favor of Uber on all claims. Thereafter, the United States Court of Appeals for the First Circuit held in Cullinane v. Uber Technologies, Inc., 893 F.3d 53 (1st Cir. 2018) that Uber's registration process did not create a contract. Thereafter, the judge reversed his decision granting the motion to compel arbitration, concluding that there was no enforceable contract requiring arbitration. The Supreme Judicial Court remanded the case, holding (1) Uber's terms and conditions did not constitute a contract with Plaintiffs; and (2) therefore, Uber could not enforce the terms and conditions against Plaintiffs, including the arbitration agreement. View "Kauders v. Uber Technologies, Inc." on Justia Law

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The Supreme Judicial Court held that certain materials requested and received by the office of the district attorney for the Suffolk district from the Federal Bureau of Investigation (FBI) related to a fatal shooting by federal and state law enforcement officials were exempt from disclosure under Mass. Gen. Laws ch. 4, 7(f).After Usaamah Rahim was killed, the district attorney opened an investigation into his death, aided by various materials provided by the FBI. Plaintiff later filed a public records request seeking documents related to Rahim's death. When the district attorney refused to provide access to the FBI materials Plaintiff sued the district attorney seeking a declaration that the FBI records were public records that must be produced under Mass. Gen. Laws ch. 66, 10. The judge granted summary judgment for the district attorney, concluding that the FBI materials were not public records. The Supreme Judicial Court held (1) the FBI materials qualified as public records under the public records law; (2) the materials were not exempt from disclosure under Mass. Gen. Laws ch. 4, 7(a) but some materials qualified for exemption under Mass. Gen. Laws ch. 4, 7(f); and (3) the remainder of the materials must be remanded to determine whether exemption (f) applies. View "Rahim v. District Attorney for the Suffolk District" on Justia Law

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The Supreme Judicial Court held that Mass. Gen. Laws ch. 279, 25(a) of the habitual offender statute allows sentencing judges to impose probation on defendants who fall within its ambit.Defendant was convicted of assault and battery with a dangerous weapon and armed assault with intent to murder. The trial judge found that section 25(a)'s enhancements applied to Defendant but rejected Defendant's argument that the statute allowed the judge to impose probation. The judge then sentenced Defendant to a term of imprisonment. The Supreme Judicial Court disagreed and vacated Defendant's sentence, holding that section 25(a) provides sentencing judges with the discretion to impose probation. View "Commonwealth v. Montarvo" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court held that the Estate of Jacqueline Ann Kendall was not required to pay a claim for reimbursement from the Commonwealth's MassHealth program when the estate proceeding was commenced more than three years after Kendall died.Kendall received MassHealth benefits in the amount of $104,738 and died intestate on August 7, 2014. On May 24, 2018, one of Kendall's heirs filed a petition for late formal testacy and notified MassHealth. MassHealth filed a notice of claim in the estate. At issue was whether the estate was required to pay the MassHealth claim more than three years after Kendall died. The Supreme Judicial Court held (1) Mass. Gen. Laws ch. 190B, 3-803(f) creates an exception for MassHealth to the general limitation on creditor claims laid out in section 3-803(a) but does not create an exception to the ultimate time limit on the personal representative's power to pay claims and creditors' ability to bring claims laid out in Mass. Gen. Laws ch. 190B, 3-108; and (2) therefore, MassHealth's claims were time barred. View "In re Estate of Kendall" on Justia Law

Posted in: Trusts & Estates
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The Supreme Judicial Court affirmed the order of the superior court denying Defendant's motion for relief from a condition of probation, holding that imposition of the condition did not violate Defendant's rights under article 14 of the Massachusetts Declaration of Rights.Defendant pleaded guilty to multiple counts of possession and dissemination of child pornography and was sentenced to concurrent terms of incarceration, suspended subject to compliance with special conditions of probation. At issue was the condition requiring Defendant to allow the probation department to conduct random suspicionless searches of his electronic devices and other locations where child pornography might be stored. Before the Supreme Court, Defendant argued that this condition authorized unreasonable searches in violation of article 14. The Court upheld the condition, holding (1) on its face, the condition subjected Defendant to the continuing possibility of unreasonable searches throughout the term of his probation and was too broad; but (2) properly limited, imposition of the condition did not violate Defendant's rights under article 14. View "Commonwealth v. Feliz" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and related charges and the order denying Defendant's motion for a new trial, holding that the trial judge did not err in denying Defendant's request that the jury be instructed on withdrawal from a joint venture.Specifically, the Supreme Court held (1) Defendant was not entitled to an instruction on withdrawal from a joint venture; (2) Defendant was not deprived of the effective assistance of counsel when counsel did not request a supplemental jury instruction to further explain the Commonwealth's burden to prove that the killing occurred during the course of the underlying felony and when counsel did not object to a portion of the prosecutor's closing argument; and (3) this Court declines to exercise its authority under Mass. Gen. Laws ch. 278, § 33E to reduce the murder conviction to murder in the second degree. View "Commonwealth v. Tillis" on Justia Law

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The Supreme Judicial Court vacated the judgment of superior court finding that the Civil Service Commission had jurisdiction to review Plaintiff's appeal of the discipline of loss of two days of accrued leave time imposed by the Department of State Police, holding that the Commission did not have subject matter jurisdiction.On appeal, the Department argued that the superior court erred in concluding that the Commission had jurisdiction over the disciplinary sanction because loss of accrued leave time does not fall within the scope of appealable matters expressly contemplated by Mass. Gen. Laws ch. 22C, 13 and Mass. Gen. Laws ch. 31, 41-45. In response, the Commission argued that even if loss of accrued leave time is not expressly contemplated by the statutes, it is equivalent to a suspension, which the Commission had jurisdiction to review. The Supreme Judicial Court agreed with the Department, holding that the Commission did not have subject matter jurisdiction under the statutes to hear Plaintiff's appeal of loss of two days of accrued leave time. View "Doherty v. Civil Service Commission" on Justia Law

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The Supreme Judicial Court held that double jeopardy barred this prosecution because the termination of Defendant's first trial was not justified by manifest necessity.The Commonwealth charged Defendant with carrying a loaded firearm, in violation of Mass. Gen. Laws ch. 269, 10(n), but did not charge him with either of the required predicate offenses of sections 10(a) or (c). At trial, the district court granted Defendant's motion for a required finding of not guilty based on the defect in charging. Thereafter, the Commonwealth obtained a second complaint charging Defendant with violating section 10(a) based on the same conduct. Defendant moved to dismiss the complaint based on double jeopardy. The Supreme Court concluded that double jeopardy barred this prosecution because there was not a manifest necessity for a mistrial. View "Commonwealth v. Taylor" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court vacated Defendant's conviction of unlawful possession of a loaded firearm, in violation of Mass. Gen. Laws ch. 269, 10(n), holding that the holding in Commonwealth v. Brown, 479 Mass. 600 (2018) that the Commonwealth must prove Defendant knew that the gun was loaded in order to establish a violation of the statute, applies retroactively to cases on collateral review.Defendant was convicted of several crimes and of a sentencing enhancement for two prior violent crimes under the Massachusetts armed career criminal act (ACCA), Mass. Gen. Laws ch. 269, 10G. The court of appeals affirmed. The Supreme Judicial Court vacated the judgment of conviction under Mass. Gen. Laws ch. 269, 10(n) and vacated so much of the judgment of conviction as pertains to the predicate offense of assault and battery by means of a dangerous weapon as to the ACCA charge, holding (1) the evidence was insufficient to support the conviction of carrying a loaded firearm; and (2) for Defendant's conviction of assault and battery by means of a dangerous weapon to count as a predicate offense for purposes of the ACCA the Commonwealth must use the modified categorical approach to prove Defendant was convicted of such a crime. View "Commonwealth v. Ashford" on Justia Law

Posted in: Criminal Law