Justia Massachusetts Supreme Court Opinion Summaries

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In this case concerning the law involving breach of an exclusive real estate broker agreement, the Supreme Judicial Court held that an enforceable contract was created in this case, Defendants committed a breach of that contract, and Plaintiff was entitled to her expectation damages.Plaintiff, a licensed real estate broker and her wholly-owned real estate brokerage firm, brought this action against Defendants, two former clients, after Plaintiff performed substantial services pursuant to the contract and Defendants terminated their relationship without paying her. Because there was no written agreement for brokerage services the motion judge granted summary judgment for Defendants. The Appeals Court reversed on the grounds that there is an express exemption to the Statute of Frauds for real estate brokers. The Supreme Judicial Court affirmed, holding that there was sufficient evidence to conclude that a contract was former and that a breach occurred, entitling Plaintiff to her expectation damages. View "Huang v. Ma" on Justia Law

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The Supreme Judicial Court remanded these consolidated cases seeking a judgment declaring the parties' respective rights to each of the remainder proceeds of two annuity contracts, holding that the cases were governed in all material respects by the Court's decision today in Dermody v. Executive office of Health & Human Servs., 491 Mass. __ (2023).In each of these cases, the Executive Office of Health and Human Services (Commonwealth) claimed entitlement to remainder proceeds of the two annuity contracts up to the amount of medical assistance paid on behalf of an institutionalized spouse, whose eligibility for Medicaid long-term care benefits was obtained through the purchase of an annuity during the relevant "look-back" period, as defined under 42 U.S.C. 1396p(c). The Supreme Judicial Court held that the Commonwealth was entitled to remainder proceeds from the annuities to the extent of benefits it paid on behalf of the institutionalized spouses in this case. View "Executive Office of Health & Human Services v. Mondor" on Justia Law

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The Supreme Judicial Court reversed the order of the superior court allowing Plaintiff's motion for summary judgment in this lawsuit brought against the Executive Office of Health and Human Services and Nationwide Life Insurance Company in this dispute over the remainder of an annuity issued by Nationwide, holding that the superior court erred.Robert Hamel purchased the annuity at issue to help Joan Hamel, his wife, become eligible for Medicaid benefits, which was necessary to pay for her long-term care. Robert named the Commonwealth as the primary remainder beneficiary to the "extent benefits paid" and Plaintiff, his daughter, as the contingent remainder beneficiary. Before the end of the annuity period Robert died. Plaintiff filed this lawsuit alleging that she was entitled to the remainder. The superior court entered summary judgment in favor of Plaintiff and denied the Commonwealth's motion for summary judgment as to Plaintiff's claim for declaratory judgment. The Supreme Judicial Court vacated and reversed the judgment below, holding that, upon Robert's passing, the remainder of the annuity properly belonged to the Commonwealth up to the amount it paid for Joan's care. View "Dermody v. Executive Office of Health & Human Services" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court denying Defendant's motion for a new trial following his conviction for murder in the first degree by means of extreme atrocity or cruelty and on the theory of felony-murder, for which his conviction of armed robbery served as the predicate offense, holding that there was no error.During trial, the Commonwealth presented expert testimony comparing hair samples collected at the crime scene with hair taken from Defendant. The testimony included a statistical probability to support the expert's opinion that the hair at issue belonged to Defendant. Due to an ensuing development finding such statistical probabilities to support hair comparisons to be unreliable Defendant filed a motion for a new trial. The motion was denied. The Supreme Judicial Court affirmed, holding that the admission of expert testimony on statistical support for hair comparison evidence, which since has been proved to be unreliable, was not a real factor in the jury's deliberations. View "Commonwealth v. Eagles" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the decision of a single justice of the court denying Petitioner's petition for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the trial justice did not commit a clear error of law or abuse his discretion in denying relief.Petitioner was convicted of armed assault with intent to murder and related charges. The Supreme Judicial Court remanded the case for a new trial, holding that the trial court prejudicially erred by admitting evidence of speed data from the GPS device worn by Petitioner. The second trial resulted in a mistrial. Petitioner filed a posttrial motion asking for a required finding of not guilty or for dismissal on double jeopardy grounds due to insufficient evidence. The trial judge denied the motion. Petitioner then brought this petition. The single justice denied relief. The Supreme Judicial Court holding (1) a rational trier of fact could reasonably infer from the evidence that Petitioner was the shooter; and (2) therefore, the single justice properly denied relief. View "Davis v. Commonwealth" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court held that there is no common-law duty for insurers to cover costs incurred by an insured to prevent imminent covered loss when the plain, unambiguous terms of the insurance policy speak directly to the question of mitigation and reimbursement and do not provide coverage and the costs are otherwise excluded by other policy provisions.Insured sought recovery from Insurer for various costs it incurred after a wastewater treatment system at its manufacturing facility malfunctioned, claiming coverage under its pollution liability policy. In dispute were costs incurred that were not cleanup costs or costs necessary to avoid imminent endangerment to public health or welfare but necessary to avoid a business interruption. The district court held that the costs at issue were not recoverable and that there was no basis to impose a common-law duty that was inconsistent with the policy's coverages and exclusions. View "Ken's Foods, Inc. v. Steadfast Insurance Co." on Justia Law

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In this case involving Salvatore F. DiMasi's attempt to register as a lobbyist with the Secretary of the Commonwealth, the Supreme Judicial Court held that Mass. Gen. Laws ch. 3, 45 (m) ("the disqualification provision") limits automatic disqualification to individuals who have been convicted of a felony set forth in Mass. Gen. Laws ch. 3, 55 or 268A.In 2011, DiMasi was convicted of seven federal felonies arising from his sale of political favors while serving as Speaker of the Massachusetts House of Representatives. In 2019, after he was released from prison, DiMasi filed his application to register as a lobbyist. The Secretary denied the application, citing the disqualification provision. The Secretary determined that, even though DiMasi was convicted of federal offenses, his application for registration as a lobbyist must be rejected because the conduct underlying his convictions would have violated Mass. Gen. Laws ch. 3 or 268A. Thereafter, DiMasi brought this lawsuit. The Supreme Judicial Court held in favor of DiMasi, holding that Mass. Gen. Laws ch. 3, 45(m) does not afford the Secretary discretion to consider what other offenses might require automatic disqualification even if the underlying criminal conduct could support a felony conviction pursuant to Mass. Gen. Laws ch. 3, 55 or 268A. View "DiMasi v. Secretary of the Commonwealth" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the decision of the juvenile court judge denying Juvenile's motion to suppress evidence of a seized firearm on the grounds that police did not have reasonable suspicion to stop her, holding that the juvenile court did not err.As a result of a report about kids displaying a firearm outside a housing complex four police officers were dispatched to the complex. One officer noticed Juvenile walking along the street who kept adjusting the waistband of her pants. The officers stopped her, conducted a patfrisk, and discovered a loaded firearm in Juvenile's waistband. After her motion to suppress was denied Juvenile entered a conditional guilty plea to four firearms-related offenses. The Supreme Judicial Court affirmed, holding that the officers had reasonable suspicion that Juvenile was carrying an illegal firearm in her waistband, and therefore, the stop and pat frisk of Juvenile comported with constitutional requirements. View "Commonwealth v. Karen K." on Justia Law

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The Supreme Judicial Court affirmed the decision of the district court granting summary judgment in favor of Seller in this case stemming from the economic disruption caused by the COVID-19 pandemic, holding that there was no error in the proceedings below.Specifically at issue was, in light of the disruptions caused by COVID-19 pandemic, whether the doctrines of impracticability of performance or frustration of purpose temporarily excused the purchaser of a cleaning services franchise and the purchaser's co-owners from their obligation to pay the outstanding portion of the purchase price of the franchise. The district court granted summary judgment in favor of the property seller. The First Circuit affirmed, holding (1) the record did not support a rational finding that the pandemic cause date continued payment of the franchise purchase price to be impracticable or frustrated the principal purpose of the contract; and (2) the parties intended that the obligation to pay would not be conditioned on the franchise's financial performance beyond the first six months following the sale. View "Le Fort Enterprises, Inc. v. Lantern 18, LLC" on Justia Law

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The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.After a jury trial, Petitioner was convicted of kidnapping, rape of a child with force, and threatening to commit a crime. The convictions were affirmed on appeal. Petitioner later filed three motions for a new trial, all of which were denied. Petitioner then filed the instant petition arguing that the appeals court erred in affirming the denial of his third new trial motion. The single justice denied relief. The Supreme Judicial Court affirmed, holding that there was no error or abuse of discretion. View "Dumas v. Commonwealth" on Justia Law

Posted in: Criminal Law