Justia Massachusetts Supreme Court Opinion Summaries

In 2020, a police officer applied for a criminal complaint in the District Court, alleging that the defendant possessed a loaded firearm while intoxicated. A clerk-magistrate denied the application, finding no probable cause that the defendant had a firearm under his control inside a motor vehicle. No review of this decision was sought. Over two years later, the same officer filed a new application for the same offense with the same facts, and a different clerk-magistrate found probable cause and issued the complaint.The defendant filed a petition for extraordinary relief, arguing that the issuance of the complaint was barred by collateral estoppel and that the delay violated his due process rights. A single justice of the county court reserved and reported the petition to the full court.The Supreme Judicial Court of Massachusetts held that the principles of collateral estoppel did not bar the issuance of the complaint because the initial denial was not a final judgment. The court noted that a District Court determination of no probable cause is not conclusive and does not bar a subsequent indictment for the same offense. The court also found no due process violation, as the defendant did not have a constitutionally protected interest in the finality of a show cause determination, and the delay did not cause severe prejudice to the defendant's ability to mount a defense. The court remanded the case to the county court for entry of a judgment denying the defendant's petition for extraordinary relief. View "Cabrera v. Commonwealth" on Justia Law

Elena Gaston was indicted on charges of trafficking persons for sexual servitude, conspiracy, deriving support from prostitution, and money laundering. The Commonwealth alleged that she ran an escort service where her employees provided sexual services for money. On the day of her trial, a plea agreement was proposed, but during the plea colloquy, Gaston denied key elements of the charges, leading the judge to proceed to trial. During the trial, defense counsel made improper opening statements, conceding Gaston's guilt and inviting the jury to consider irrelevant factors, which led the Commonwealth to move for a mistrial.The trial judge initially opted for a curative instruction instead of a mistrial but later declared a mistrial after concluding that defense counsel's actions constituted ineffective assistance of counsel. The judge noted that defense counsel's failure to consult with Gaston on his opening statement and the detrimental impact of his strategy on her defense warranted a mistrial. Gaston, represented by new counsel, filed a motion to dismiss the indictments on double jeopardy grounds, which the trial judge denied.Gaston then filed a petition in the county court seeking relief from the denial of her motion to dismiss. The petition was denied by a single justice, and she appealed to the Supreme Judicial Court. The Supreme Judicial Court affirmed the single justice's decision, holding that the trial judge did not abuse his discretion in declaring a mistrial due to manifest necessity. The court found that the trial judge carefully considered alternatives and provided both parties with opportunities to be heard before declaring a mistrial. The court concluded that defense counsel's conduct was manifestly unreasonable and deprived Gaston of a substantial ground of defense, justifying the mistrial. View "Gaston v. Commonwealth" on Justia Law

Susan Miele was hired by Foundation Medicine, Inc. (FMI) in 2017 and signed a restrictive covenant agreement that included a nonsolicitation provision. In 2020, Miele and FMI executed a transition agreement upon her separation, which incorporated the restrictive covenant agreement and included a forfeiture clause. FMI paid Miele approximately $1.2 million in transition benefits. After joining Ginkgo Bioworks in 2021, Miele allegedly solicited FMI employees to join Ginkgo, leading FMI to cease further payments and demand repayment of benefits.Miele sued FMI in late 2021 for breach of the transition agreement, and FMI counterclaimed for breach of contract. Miele moved for judgment on the pleadings, arguing that the provisions FMI relied on were unenforceable under the Massachusetts Noncompetition Agreement Act. A Superior Court judge granted Miele's motion in part, ruling that FMI could not enforce the forfeiture provision but allowed FMI to assert Miele's breach as a defense and seek damages. The judge concluded that the transition agreement qualified as a "forfeiture for competition agreement" under the act.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the Massachusetts Noncompetition Agreement Act does not apply to a nonsolicitation agreement, even if it includes a forfeiture provision. The court reasoned that the act explicitly excludes nonsolicitation agreements from its scope, and a forfeiture clause does not change this exclusion. The court reversed the Superior Court's order partially granting Miele's motion for judgment on the pleadings and remanded the matter for further proceedings consistent with its opinion. View "Miele v. Foundation Medicine, Inc." on Justia Law

The case involves the execution of an anticipatory search warrant that led to the seizure of cocaine and U.S. currency from Victor Manuel Mercedes' apartment. The warrant was contingent on a future triggering event, which did not occur. The issue is whether the police could still search the apartment based on other information in the warrant affidavit that independently established probable cause.In the Superior Court, a grand jury indicted the defendant on drug trafficking charges. A codefendant's motion to suppress evidence from a related search was granted, and the defendant joined this motion. The judge allowed the motion, ruling that the anticipatory warrant was void because the triggering event did not occur. The Commonwealth appealed, arguing that the search was valid based on probable cause from other information in the affidavit.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that under Article 14 of the Massachusetts Declaration of Rights, police cannot execute an anticipatory search warrant without the occurrence of the specified triggering event or its equivalent. The court emphasized that the triggering event must be clear and narrowly defined to prevent police from exercising unfettered discretion. The court affirmed the lower court's decision to suppress the evidence, ruling that the anticipatory warrant was void without the triggering event, and no valid exception to the warrant requirement was established. The defendant's cross-appeal was dismissed. View "Commonwealth v. Mercedes" on Justia Law

In 2023, Boima Collins was convicted by a jury of carrying a firearm without a license and other charges. The Commonwealth introduced evidence of Collins' 1998 felony conviction to prove he did not have a license to carry a firearm, as a prior felony conviction bars one from obtaining such a license. The trial judge admitted the redacted court record over Collins' objection and instructed the jury to consider this evidence only for determining whether Collins had a license.Collins appealed, arguing that the trial judge abused her discretion by admitting the prior conviction evidence, claiming it was more prejudicial than probative and that the Commonwealth had less prejudicial means to prove lack of licensure. He also contended that the jury should have been instructed to consider the prior conviction evidence only if the Commonwealth proved beyond a reasonable doubt that he was the person named in the record. Additionally, Collins argued that the evidence was insufficient to prove he lacked a license because the Commonwealth did not prove he was the same person named in the record.The Supreme Judicial Court of Massachusetts reviewed the case and found no prejudicial error in admitting the evidence of Collins' prior conviction. The court held that the trial judge correctly weighed the evidence's probative value against the risk of unfair prejudice, provided robust limiting instructions to the jury, and noted that the prior conviction was for a dissimilar offense, reducing the risk of improper propensity reasoning. The court also concluded that the judge's instructions to the jury were not erroneous and that the evidence was sufficient to prove Collins lacked a firearms license. Consequently, the court affirmed Collins' convictions. View "Commonwealth v. Collins" on Justia Law

The defendant was convicted of assault and battery by means of a dangerous weapon after stabbing his father at a family barbecue. The incident occurred when the victim became upset and yelled at the defendant's wife, leading to a confrontation between the defendant and the victim. The victim pushed the defendant first, and the defendant responded by stabbing the victim in the chest. The defendant claimed he acted in self-defense and sought to introduce evidence of the victim's subsequent violent act to support his claim.The case was initially tried in the Superior Court, where the defendant was convicted. The judge denied the defendant's motion to introduce evidence of the victim's subsequent violent act, concluding that such evidence was not admissible under Commonwealth v. Adjutant. The defendant appealed, and the Supreme Judicial Court transferred the case from the Appeals Court on its own initiative.The Supreme Judicial Court of Massachusetts reviewed the case and held that the judge erred in believing that Adjutant evidence is not applicable to subsequent acts of violence. However, the court affirmed the conviction, stating that the evidence was correctly excluded because the identity of the first aggressor was not in dispute, and the defendant was the first to use deadly force. The court also held that the judge did not err in failing to instruct the jury on defense of another, as the defendant did not rely on this theory at trial, and no evidence suggested that the defendant reasonably believed he had to use deadly force to protect his wife. The judgment was affirmed. View "Commonwealth v. Andrade" on Justia Law

The case involves the admissibility of location data obtained from a GPS device imposed on the defendant as a condition of pretrial release. The defendant was involved in a domestic violence incident on December 26, 2019, where he threatened his ex-wife, C.P., and discharged a firearm. He was later apprehended in July 2020 and released on bail with conditions, including GPS monitoring. In August 2020, following a shooting incident, police retrieved the defendant's GPS data to determine his proximity to the crime scene.The Superior Court denied the defendant's motion to suppress the GPS evidence, and he entered a conditional guilty plea, reserving the right to appeal the suppression ruling. The case was transferred to the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court addressed two main issues: whether the initial imposition of GPS monitoring was an unreasonable search under Article 14 of the Massachusetts Declaration of Rights, and whether the subsequent retrieval and review of the defendant's GPS data constituted an unreasonable search.The court held that the initial imposition of GPS monitoring was a search but was reasonable under Article 14 due to the legitimate governmental interests in protecting the alleged victims and ensuring compliance with the conditions of pretrial release. The court found that the defendant's privacy expectations were outweighed by these interests.Regarding the retrieval and review of the GPS data, the court concluded that it did not constitute a search under Article 14. The defendant did not have a reasonable expectation of privacy in the specific location data retrieved, as it was limited in scope and duration, and the defendant was aware that his movements could be monitored for compliance with pretrial conditions.The Supreme Judicial Court affirmed the lower court's order denying the motion to suppress. View "Commonwealth v. Govan" on Justia Law

In 2023, Kenneth Bresler, a former Appeals Court staff attorney, filed a lawsuit in the Superior Court against three Appeals Court employees, Lynn Muster, Mary Bowe, and Gina DeRossi, alleging intentional interference with advantageous relations. Bresler claimed that the defendants engaged in a campaign that led to his termination. The defendants moved to dismiss the complaint, arguing that Bresler failed to establish the "actual malice" required for such a claim and that they were entitled to common-law immunity as public officials.The Superior Court judge granted the motion to dismiss for Bowe and DeRossi but denied it for Muster. Bresler appealed the dismissal of Bowe and DeRossi, while Muster cross-appealed the partial denial of her motion to dismiss. The Supreme Judicial Court granted Bresler's application for direct appellate review.The Supreme Judicial Court reviewed the case and concluded that the allegations in the complaint, when taken as true, plausibly suggested that Muster and Bowe acted with "actual malice," which is necessary to state an intentional interference claim. The court found that Muster's actions, motivated by jealousy and hostility, and Bowe's subsequent negative evaluations and actions against Bresler, supported the inference of actual malice. However, the court held that the complaint did not contain sufficient factual allegations to establish actual malice or defeat common-law immunity for DeRossi.As a result, the Supreme Judicial Court affirmed the Superior Court's order as to Muster and DeRossi and reversed it as to Bowe, allowing the claims against Muster and Bowe to proceed while dismissing the claims against DeRossi. View "Bresler v. Muster" on Justia Law

The case involves a dispute between two parents, Bharathan Jeevanandam and Vanikala Bharathan, regarding child support payments. The parents divorced in 2012, and the father was ordered to pay child support to the mother, who had primary physical custody of their child. In 2021, the father filed a complaint for modification, seeking to terminate his child support obligation because the child was enrolled in a full-time residential program paid for by the municipalities. The Probate and Family Court terminated the father's child support obligation retroactively to January 1, 2022.The father then sought reimbursement from the mother for the child support payments made after the retroactive termination date. The Probate and Family Court ordered the mother to repay the father at a rate of $80 per week through the Department of Revenue Child Support Enforcement Division. The department, however, contended that it lacked the authority to enforce the reimbursement order because it was not an order for child support. The judge denied the department's motion for reconsideration, leading to the department's appeal.The Supreme Judicial Court of Massachusetts reviewed the case and determined that the Department of Revenue does not have the authority to enforce a judgment requiring one parent to reimburse the other for overpayment of child support when the reimbursement does not go to support the child. The court held that the department's enforcement authority is confined to judgments, decrees, and orders that are "for the support and maintenance of a child" as defined by G. L. c. 119A, § 1A. Since the reimbursement in this case did not go to support or maintain the child, the court vacated the portion of the second amended judgment that required the department to enforce the reimbursement obligation through wage assignment. View "Jeevanandam v. Bharathan" on Justia Law

The defendant was charged with operating a motor vehicle while under the influence of alcohol (OUI), third offense, resisting arrest, and three civil motor vehicle violations. After being stopped by police, the defendant exhibited signs of intoxication and was arrested. At the police station, he refused a breath test and was taken to a hospital where blood tests were conducted as part of his medical treatment. The police obtained a search warrant for the defendant's blood samples and sent them to the State police crime laboratory for analysis. The defendant moved to suppress the blood sample evidence, arguing he did not consent to the blood test.The motion to suppress was allowed by the lower court, which ruled that the blood sample and any analysis conducted by the State police were inadmissible. The Commonwealth obtained the defendant's medical records, which included the blood test results, and a forensic scientist converted these results to a blood alcohol content (BAC) percentage. The defendant moved to exclude this converted BAC evidence, and the trial judge agreed, reasoning that it was derived from suppressed evidence. The Commonwealth's motion for reconsideration was denied, and they petitioned for extraordinary relief.The Supreme Judicial Court of Massachusetts reviewed the case and held that the consent provision of General Laws c. 90, § 24 (1) (e), which requires a defendant's consent for the admissibility of blood or breath test results conducted by or at the direction of police, does not apply to the mathematical conversion of serum/plasma ethanol results from medical records to a BAC percentage. The court concluded that this conversion is not a "chemical analysis" as defined by the statute. Therefore, the converted BAC evidence is admissible, and the lower court's decision to exclude it was reversed. The case was remanded for further proceedings consistent with this opinion. View "Commonwealth v. Gannett" on Justia Law