Justia Massachusetts Supreme Court Opinion Summaries

The defendant was convicted of murder in the first degree, armed assault with intent to murder, and assault and battery by means of a dangerous weapon. The charges stemmed from his role as the getaway driver after a shooting in Charlestown, Boston, where two men in hooded sweatshirts shot Ryan Morrissey and Jamie Lawton outside a convenience store, killing Morrissey and seriously injuring Lawton. Witnesses saw the assailants flee on foot and enter a car driven by the defendant. The car was later identified as belonging to the defendant's mother.In the Superior Court, the defendant was tried jointly with two alleged assailants, Danilo Soto and Alexander Soto, who were acquitted by the jury. The defendant was found guilty on all charges. He appealed, arguing insufficient evidence to prove he was the driver and that he shared the assailants' lethal intent. He also challenged the trial judge's decisions on jury selection and the admissibility of expert testimony.The Supreme Judicial Court of Massachusetts reviewed the case. The court found sufficient evidence to establish that the defendant was the getaway driver. However, it concluded that there was insufficient evidence to prove that the defendant knew of or shared the assailants' lethal intent. The court emphasized that the evidence did not show the defendant knew the assailants were armed or intended to kill the victims. Consequently, the court reversed the defendant's convictions of murder in the first degree, armed assault with intent to murder, and assault and battery by means of a dangerous weapon, and remanded the case for entry of a required finding of not guilty. View "Commonwealth v. Baez" on Justia Law

A severe thunderstorm caused significant damage to Norwood Hospital, owned by Medical Properties Trust, Inc. (MPT) and leased to Steward Health Care System LLC (Steward). The storm led to extensive flooding in the hospital's basements and rainwater accumulation on the rooftop courtyard and parapet roofs, which then seeped into the building, causing further damage. MPT and Steward sought coverage from their insurers, Zurich American Insurance Company (Zurich) and American Guarantee and Liability Insurance Company (AGLIC), respectively. Both policies had high overall coverage limits but lower sublimits for flood damage. The insurers argued that all the damage was due to "Flood" as defined in the policies, which included "surface waters," and thus subject to the lower sublimits.The United States District Court for the District of Massachusetts granted partial summary judgment to the insurers, interpreting "surface waters" to include rainwater accumulated on the roofs. The court allowed an interlocutory appeal, recognizing the substantial ground for difference of opinion on this legal issue. The United States Court of Appeals for the First Circuit then certified the question to the Supreme Judicial Court of Massachusetts, asking whether rainwater accumulating on a building's rooftop courtyard or parapet roof constitutes "surface waters" under Massachusetts law.The Supreme Judicial Court of Massachusetts concluded that the term "surface waters" is ambiguous in this context. The court noted the lack of a clear definition in the policies and the divided case law on the issue. Given this ambiguity, the court ruled in favor of the insureds, determining that rainwater accumulating on the rooftop courtyard and parapet roofs does not unambiguously constitute "surface waters" under the policies. Therefore, the damage from such water infiltration is not subject to the flood sublimits. View "Zurich American Insurance Company v. Medical Properties Trust, Inc." on Justia Law

The defendant was convicted of reckless endangerment of a child and witness intimidation after attacking her twelve-year-old son. The incident began with an argument about the son's dental braces, leading the defendant to contemplate suicide. The next morning, she attempted to kill her son by stabbing him in the neck and trying to drown him. The son managed to escape and tried to call 911, but the defendant took his phone and told the dispatcher everything was fine. The son eventually called the police, who found him injured and the defendant attempting to harm herself.The defendant was indicted on multiple charges, including assault and battery by means of a dangerous weapon and attempted murder. After a bench trial, the Superior Court judge found her not guilty by reason of mental illness for the assault and attempted murder charges but guilty of reckless endangerment and witness intimidation. She was sentenced to five years of probation with conditions, including no unsupervised contact with her children and GPS monitoring for two years. The defendant appealed, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court upheld the convictions, finding sufficient evidence that the defendant was criminally responsible for her actions after the attack. The court determined that the defendant understood the criminality of preventing her son from calling 911 and could conform her conduct to the law. The court also found the indictment for reckless endangerment was not impermissibly ambiguous and that the GPS monitoring condition of probation was reasonable. The court affirmed the convictions and the probation condition. View "Commonwealth v. Rezac" on Justia Law

The case involves the defendant, Maryann Russo, who was charged with animal cruelty under G. L. c. 272, § 77, for her treatment of her terminally ill fourteen-year-old cocker spaniel, Tipper. Russo brought Tipper to a veterinarian who recommended euthanasia due to Tipper's severe health issues, including a large necrotic mass, bed sores, and open wounds. Russo declined euthanasia, falsely stating she would take Tipper to another veterinarian, and instead took him home. The Animal Rescue League (ARL) later removed Tipper from Russo's care after the veterinarian reported her suspicions. Tipper was found in poor condition and was subsequently euthanized.In the Quincy Division of the District Court, a criminal complaint was issued against Russo in February 2021. Russo filed a motion to dismiss the complaint, arguing it lacked probable cause. The District Court judge granted the motion, concluding that the statute did not impose an affirmative obligation to euthanize an animal. The Commonwealth appealed, and the Appeals Court affirmed the dismissal, reasoning that the statute did not criminalize the failure to euthanize an animal. The Supreme Judicial Court granted further appellate review.The Supreme Judicial Court affirmed the dismissal, holding that the Commonwealth failed to establish probable cause that Russo acted with the requisite criminal intent. The court concluded that the statute required proof that Russo knowingly and willfully authorized or permitted Tipper to be subjected to unnecessary suffering. The court found that Russo's actions, including seeking medical care and attempting to make Tipper comfortable, did not indicate an intent to cause unnecessary suffering. The court emphasized that speculation alone was insufficient to establish probable cause. View "Commonwealth v. Russo" on Justia Law

In 2016, the Federal National Mortgage Association (Fannie Mae) acquired the high bid at a foreclosure sale of Anthony Michael Branch's property. Fannie Mae then initiated a summary process action in the Housing Court to gain possession. The court ruled in favor of Fannie Mae, and Branch appealed. During the appeal, Fannie Mae sold the property to Roberto Pina Cardoso. Cardoso intervened in the case and was awarded use and occupancy payments from Branch. The Appeals Court later vacated the Housing Court's judgment for possession, declaring it moot since Fannie Mae no longer had a possessory interest, and required Cardoso to establish his right to possession in a new case.The Housing Court initially granted summary judgment in favor of Fannie Mae for possession and dismissed Branch's counterclaims. Branch appealed, and during the appeal, Cardoso was allowed to intervene and was joined as a party with Fannie Mae. The Appeals Court vacated the judgment for possession as moot but affirmed the dismissal of Branch's counterclaims.The Supreme Judicial Court of Massachusetts reviewed the case and disagreed with the Appeals Court's mootness determination. The court held that Cardoso, having acquired Fannie Mae's interest, maintained a live stake in the adjudication of the judgment for possession. The court affirmed the Housing Court's order allowing Cardoso to intervene and be joined as a party. It also affirmed the summary judgment in favor of Fannie Mae for possession and the dismissal of Branch's counterclaims. The court concluded that the foreclosure was valid and that Pentagon Federal Credit Union, as the authorized agent of the note holder, had the authority to foreclose. View "Fannie Mae v. Branch" on Justia Law

The defendant was convicted of first-degree murder for the stabbing death of Jordan Baskin. After his conviction, the defendant filed a motion for a new trial, claiming his trial counsel provided ineffective assistance during a police interview where incriminating evidence was obtained. The defendant argued that his trial counsel failed to provide effective representation and had a conflict of interest because filing a motion to suppress the evidence would have been against her own interests.The Superior Court judge allowed the motion for a new trial, finding that the trial counsel had an actual conflict of interest and that the defendant did not waive this conflict knowingly and intelligently. The judge concluded that the conflict alone warranted a new trial without needing to show additional prejudice.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The court found that the trial counsel's personal interests materially interfered with her independent professional judgment, creating an actual conflict of interest. This conflict arose because the trial counsel's performance during the police interview was in question, and she could not provide detached advice or pursue a motion to suppress the evidence obtained during the interview zealously. The court also determined that the defendant did not validly waive this conflict, as the colloquies before trial did not address the specific conflict related to the adequacy of counsel's performance at the police interview. Therefore, the court affirmed the order for a new trial. View "Commonwealth v. Brown" on Justia Law

The case involves Pure Oasis LLC, which applied for a conditional use permit to operate a recreational cannabis dispensary in Boston. The building commissioner denied the permit, and Pure Oasis appealed to the Board of Appeal of Boston. After multiple hearings, the board approved the permit. William Shoucair, an abutter to the property, opposed the permit, arguing it would negatively impact the neighborhood and filed a complaint in the Superior Court in Suffolk County, appealing the board's decision.The Superior Court judge ordered each plaintiff to post a $3,500 bond, despite not finding the appeal to be in bad faith. The judge applied the standard from Damaskos v. Board of Appeal of Boston, which allows for a bond to discourage frivolous appeals while not obstructing meritorious ones. The plaintiffs sought interlocutory review, and a single justice of the Appeals Court stayed the bond order and allowed an interlocutory appeal. The Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that under Section 11 of the Boston zoning enabling act, a preliminary finding of bad faith or malice is not required before imposing a bond for damages. The court reaffirmed the standard from Damaskos, which balances discouraging frivolous appeals with not obstructing meritorious ones. The court found no abuse of discretion by the lower court judge in setting the bond amount and affirmed the order. View "Shoucair v. Board of Appeal of Boston" on Justia Law

In November 2004, a sixteen-year-old juvenile stalked and robbed a victim at gunpoint, repeatedly raped her in her home, and then bound, gagged, and robbed her roommate when she arrived. He was sentenced to state prison for aggravated rape and other offenses, with a period of parole ineligibility compliant with constitutional requirements. After serving his prison term, he was placed on probation for the remaining nonhomicide offenses.In March 2007, the juvenile was adjudicated as a youthful offender and sentenced to sixteen to twenty years in state prison for aggravated rape, with additional concurrent and consecutive sentences for other offenses. In 2021, following a court decision, his sentence was restructured to comply with constitutional requirements, reducing his parole ineligibility to fifteen years. He was released from prison in January 2022 and began a five-year probation term. In August 2022, he was arrested for new offenses, leading to a probation violation notice and detention.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the restructured sentence, including the probation term, did not violate constitutional protections against cruel or unusual punishment. The court emphasized that the probation term provided the juvenile with an opportunity for rehabilitation and reintegration into the community. The court also noted that any potential further incarceration resulting from a probation violation would be subject to constitutional constraints, ensuring that the juvenile would not be treated more harshly than a juvenile convicted of murder for parole eligibility purposes. The court affirmed the order denying the juvenile's motion for relief from unlawful restraint. View "Commonwealth v. Sajid S." on Justia Law

The case revolves around the defendant, Mark O'Brien, who was convicted of first-degree murder for the killing of Robert McKenna. The murder occurred during a robbery scheme where O'Brien and his two co-venturers entered McKenna's home to steal marijuana, a firearm collection, and other valuables. The robbery turned violent when they found McKenna awake, leading to a struggle where they struck McKenna repeatedly in the head with a metal frying pan, causing his death. No DNA or other forensic evidence placed O'Brien at the scene, leading to his defense that he was not the third co-venturer.The Superior Court Department found and returned indictments against O'Brien on November 24, 2015. The cases were tried before Jeffrey A. Locke, J., and a motion for a new trial, filed on August 27, 2021, was heard by Mark A. Hallal, J. O'Brien was convicted of murder in the first degree and twelve other charges. He appealed his conviction and also filed a motion for a new trial, arguing that he received ineffective assistance of counsel because his trial counsel withdrew a request for an involuntary manslaughter jury instruction.The Supreme Judicial Court of Massachusetts reviewed the case and found no error in the lower court's proceedings. The court held that the defendant's counsel's decision to withdraw the request for an involuntary manslaughter instruction was not manifestly unreasonable given the evidence. The court also found no prosecutorial misconduct in the handling of the informant's testimony or the closing argument. However, the court vacated the defendant's convictions of unlawful possession of a firearm and remanded those charges for a new trial, in light of a recent Supreme Court decision requiring the prosecution to prove lack of licensure. The court affirmed the defendant's other convictions and the order denying his motion for a new trial. View "Commonwealth v. O'Brien" on Justia Law

The case involves two groups of plaintiffs, referred to as the Schneider plaintiffs and the Page plaintiffs, who challenged the title and one-sentence "yes/no" statements prepared by the Attorney General and the Secretary of the Commonwealth (Secretary) for Initiative Petition 23-36. This petition proposed to replace the Massachusetts Comprehensive Assessment System (MCAS) tests, currently used as a measure of student competency for high school graduation, with a system where students must satisfactorily complete coursework certified by their district as showing mastery of state academic standards.The plaintiffs filed their complaints in the Supreme Judicial Court for Suffolk County, arguing that the title and one-sentence statements were misleading and inconsistent with the requirements of G. L. c. 54, § 53. The Page plaintiffs contended that the statements only mentioned the elimination of MCAS without stating that it would be replaced with something else. The Schneider plaintiffs argued that the statements did not disclose that the petition would prohibit the use of any uniform statewide assessment as a graduation requirement.The Supreme Judicial Court of Massachusetts found that the title and one-sentence statements accurately characterized the petition's proposal to eliminate MCAS tests as a graduation requirement. The court noted that while the petition also proposed a new assessment scheme and prohibited any future statewide assessment from being used as a graduation requirement, these were not distinct regulatory features of the petition. The court concluded that the title and one-sentence statements did not need to describe every feature of the petition. The court also rejected the additional arguments forwarded by the Page plaintiffs. The court remanded the matter to the county court for entry of a judgment declaring that the Attorney General and Secretary's title and one-sentence statements were in compliance with the requirements of G. L. c. 54, § 53. View "Schneider v. Attorney General" on Justia Law