Justia Massachusetts Supreme Court Opinion Summaries

A woman was charged in connection with the death of her eleven-month-old niece, who had been left in her care for several hours. The infant, previously healthy, was found unresponsive, and surveillance footage captured the sounds of crying and a sequence of thuds before the defendant called 911. Medical personnel observed a bruise on the child’s head, and subsequent hospital treatment and autopsy revealed acute subdural hematoma, brain swelling, and multiple bruises. Expert witnesses for the prosecution testified that the injuries were consistent with abusive head trauma, while the defense experts posited that the child suffered from chronic subdural bleeding and that a minor bump could have caused a rebleed.The defendant was indicted for first-degree murder in the Massachusetts Superior Court. Prior to trial, the judge conducted a Daubert-Lanigan hearing on the admissibility of expert testimony regarding abusive head trauma. The judge ruled experts could testify that the injuries were “consistent with” abusive head trauma but could not state that such trauma definitively caused the death. Testimony was also limited regarding the causation of such trauma by short falls. At trial, the jury convicted the defendant of involuntary manslaughter under theories of battery and wanton or reckless conduct. The defendant’s motions for a required finding of not guilty were denied.On appeal, the Supreme Judicial Court of Massachusetts reviewed whether there was sufficient evidence for conviction and if the trial judge abused discretion in admitting expert testimony. The Court held the evidence was sufficient for a rational jury to find the elements of involuntary manslaughter beyond a reasonable doubt. The Court also held that the trial judge did not abuse discretion in admitting expert testimony that the injuries were “consistent with” abusive head trauma, finding the diagnosis generally accepted in the medical community. The judgment of conviction was affirmed. View "Commonwealth v. Hsu" on Justia Law

The case concerns a fatal incident that took place in November 2020. The defendant, along with two associates, was involved in a series of events that led to the stabbing death of a marijuana dealer at the dealer’s apartment. The defendant and one associate entered the victim’s home, while the third person waited outside in a car. After the stabbing, the defendant and his associate fled with bags containing marijuana and other items, and quickly left the scene. Evidence indicated that the defendant discarded bloody clothing and attempted to evade authorities by purchasing a bus ticket under a false identity. No murder weapon was recovered, but forensic evidence linked the defendant to the crime.The case was tried in the Massachusetts Superior Court. The defendant and the associate who waited outside were both charged, while the direct participant in the stabbing died before trial. The defendant was convicted of armed robbery and murder in the first degree under a felony-murder theory. The associate was convicted as an accessory after the fact, and that conviction was affirmed by the Massachusetts Appeals Court. The defendant appealed, arguing that the evidence was insufficient for felony-murder and that the trial judge should have instructed the jury on larceny as a lesser included offense.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the evidence was sufficient for a rational jury to find the defendant guilty of felony-murder predicated on armed robbery, either as a principal or joint venturer. The court also found that the trial judge was not required to instruct the jury on larceny, given the defendant’s trial strategy and the absence of a request for such an instruction. The defendant’s convictions and the judgments of the lower court were affirmed. View "Commonwealth v. Henderson" on Justia Law

The dispute involves the town of Nahant and Northeastern University over a peninsula known as East Point. Northeastern owns most of the land, using part for its Marine Science Center, while the town owns a smaller parcel at the tip, which it maintains as a public park. The town also holds an easement over Northeastern’s property for access to the park. In 2018, Northeastern announced plans to expand its campus with a new building, sparking local opposition. In response, Nahant residents voted in 2021 to authorize the town’s board of selectmen to use eminent domain to acquire conservation and access easements across portions of Northeastern’s property. The town then petitioned the Massachusetts Superior Court to establish its right to take these property interests.Northeastern challenged the taking, arguing it was undertaken in bad faith, claiming the town’s real motive was to block its development project. On cross motions for summary judgment, the Superior Court judge sided with Northeastern, finding that the town’s stated public purpose was pretextual and that its true intent was to prevent the proposed expansion. As a result, the judge dismissed the town’s petition and awarded Northeastern over $1 million in fees and costs.The Supreme Judicial Court of Massachusetts reviewed the case on direct appellate review. It held that Nahant’s stated purposes for the taking—conservation, open space, and public access—constitute valid public purposes under Massachusetts law. The Court found no reasonable expectation that Northeastern could prove the town acted in bad faith or that the taking was improperly motivated by private interests, and rejected alternative public policy arguments. The Court reversed the Superior Court’s judgment, vacated the fee award, and remanded for entry of an order establishing the town’s right to take the property interests, and for further proceedings. View "Town of Nahant v. Northeastern University" on Justia Law

The defendant pleaded guilty in 1995 to two counts of second-degree murder and several related charges after confessing to the shooting deaths of Tracy Brown and Celine Kirk in Boston. Evidence included ballistics matching a weapon used in a prior shooting, witness identification, and a confession detailing facts only the perpetrator would know. The plea resulted in two consecutive life sentences with parole eligibility and concurrent sentences for other charges.Prior to this appeal, the defendant filed multiple motions in the Massachusetts Superior Court to withdraw his guilty pleas, arguing ineffective assistance of counsel and issues with discovery. These motions were denied, and the Massachusetts Appeals Court affirmed the denials. In 2020, the defendant filed another motion for a new trial, asserting that undisclosed exculpatory evidence and newly discovered evidence from the investigation into Detective John Mulligan's murder, as well as alleged police misconduct and a protective order restricting access to certain materials, undermined the voluntariness of his plea and counsel’s effectiveness. After an evidentiary hearing, the Superior Court judge denied the motion, finding no material prejudice and that the defendant’s decision to plead guilty was rational given the strong evidence against him.The Supreme Judicial Court of Massachusetts reviewed the case on direct appellate review. It held that the defendant failed to demonstrate a reasonable probability that he would have rejected the plea offer had he known of the undisclosed or newly discovered evidence, and did not show that rejecting the plea would have been rational. The court found no nexus between alleged police misconduct and the investigation of the defendant’s case, and concluded the confession was voluntary. The order denying the motion to vacate the guilty pleas and for a new trial was affirmed. View "Commonwealth v. Hood" on Justia Law

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