Justia Massachusetts Supreme Court Opinion Summaries

The case involves a nonmarital child who was removed from the mother's custody due to neglect. The Department of Children and Families filed a care and protection petition in the Juvenile Court. The father, who had established paternity but had not sought custody prior to the filing of the petition, was granted temporary custody. The mother later waived her right to a hearing and stipulated that she was unfit, leading to the Juvenile Court judge awarding "permanent" custody to the father. However, the child filed a motion to dismiss the care and protection case, arguing that the Juvenile Court's custody order was sufficient to award permanent custody to the father.The Juvenile Court judge denied the child's motion, citing the statutory scheme which addresses the rights and responsibilities of the parents of nonmarital children. This scheme provides that the mother of a nonmarital child "shall" have custody "[i]n the absence of an order or judgment of a [P]robate and [F]amily [C]ourt [judge] relative to custody." The current practice in the Juvenile Court is to require the parent, who has been awarded permanent custody of the child in connection with a care and protection action, to seek an order of custody from the Probate and Family Court under the nonmarital child statutory scheme.The Supreme Judicial Court of Massachusetts affirmed the Juvenile Court judge's order denying the child's motion to dismiss the care and protection case. The court agreed that the current practice best reflects the Legislature's intent and harmonizes the two statutory schemes. The court also concluded that the practice complies with due process. View "Care and Protection of Jaylen" on Justia Law

In 2005, Leon Robinson was convicted of first-degree murder and unlawful possession of a firearm for the 2001 shooting death of Recardo Robinson. The incident occurred in a barbershop after an argument between the two men. Several witnesses identified Leon as the shooter. The prosecution also presented evidence of a small bloodstain on Leon's jacket that matched the victim's DNA. Leon appealed his convictions and the denial of his motion for a new trial, arguing that evidence obtained from his apartment was wrongly admitted, his right to self-representation was violated, the prosecutor acted improperly, and his counsel was ineffective.The Superior Court Department had previously denied Leon's pretrial motion to suppress evidence from his apartment. Leon argued that the search warrant was erroneously granted, but the Supreme Judicial Court disagreed, finding that the warrant was supported by probable cause. Leon's motion for a new trial was also denied by the Superior Court Department. He argued that his trial counsel was ineffective for not introducing certain evidence and not retaining expert witnesses, but the Supreme Judicial Court found these decisions to be strategic and not manifestly unreasonable.The Supreme Judicial Court affirmed Leon's murder conviction, finding no errors that would have influenced the jury's decision. However, the court vacated his conviction for unlawful possession of a firearm. The court ruled that, in light of a recent U.S. Supreme Court decision, the absence of a license was an essential element of the firearm possession offense that the prosecution needed to prove. The case was remanded for a new trial on the firearm charge. View "Commonwealth v. Robinson" on Justia Law

The case revolves around the interpretation of a will and the application of the anti-lapse statute. Heather W. Hossack, the testator, had devised certain assets to her mother, Ethel Wyman, "if she survives me." However, Wyman predeceased Heather. John A. Hossack, Heather's brother, argued that the anti-lapse statute required that the failed devise fall to him. Thomas Gibney, the named beneficiary of the residuary estate, sought a declaration that the phrase "if she survives me" showed Heather's intent to avoid the application of the anti-lapse statute.The case was initially heard in the Essex Division of the Probate and Family Court Department, where the judge allowed summary judgment in favor of Gibney. John appealed the decision, and the Supreme Judicial Court transferred the case from the Appeals Court.The Supreme Judicial Court affirmed the decision of the lower court. The court held that the phrase "if she survives me" demonstrated Heather's intent to avoid the application of the anti-lapse statute. The court reasoned that Heather had contemplated the possibility of Wyman predeceasing her and had expressly provided for it in the will. Therefore, the anti-lapse statute's presumed intention had to yield to the expressed intention of the testator. The court also noted that the will as a whole supported this conclusion, as it specified that a devisee is only considered to have "survived" Heather if the devisee survives her for at least ninety days. View "Gibney v. Hossack" on Justia Law

The case involves Terrence Tyler, who was convicted of felony-murder in the first degree with the predicate felony of attempted unarmed robbery and assault with intent to rob. The incident occurred during a planned robbery of a marijuana dealer, Wilner Parisse, who was shot and killed during a physical altercation. Tyler appealed his conviction and filed two motions for a new trial. The first motion argued that his trial counsel was ineffective for not requesting an involuntary manslaughter jury instruction. The second motion requested the retroactive application of a court decision (Commonwealth v. Brown) that abolished felony-murder as an independent theory of liability for murder. Both motions were denied.The Supreme Judicial Court of Massachusetts reviewed Tyler's case and his motions for a new trial. The court held that the rule in Brown was intended to apply prospectively, and there was no reason to depart from that limitation. The court also found that Tyler's trial counsel did not err by failing to request an involuntary manslaughter instruction, as the pre-Brown default rule applies here. The court further held that the trial judge's instruction did not allow the jury to find Tyler guilty of felony-murder for conduct only sufficient to convict him of manslaughter. The court declined to reduce the verdict of murder in the first degree to a lesser degree of guilt. Therefore, Tyler's conviction was affirmed, and the orders denying his motions for a new trial were also affirmed. View "Commonwealth v. Tyler" on Justia Law

The Supreme Judicial Court of Massachusetts heard an appeal involving Bradley Zucchino, who was charged with operating a motor vehicle under the influence of alcohol, causing serious bodily injury and death. Zucchino challenged the admissibility of his blood alcohol content (BAC) evidence, arguing that it was collected without his consent, contravening G. L. c. 90, § 24 (1) (e). The court had to determine whether the Commonwealth needed the defendant's consent to admit his BAC results in the prosecution of a G. L. c. 90, § 24L (OUI-SBI) offense.The court determined that the language of G. L. c. 90, § 24 (1) (e) was clear and unambiguous, applying specifically to violations of § 24 (1) (a), or simple OUI. The court noted that if the Legislature had intended the consent requirement of § 24 (1) (e) to apply to aggravated OUI offenses, it would have made this explicit. The court stated that it is within the Legislature's purview to treat simple OUI and aggravated OUI offenses differently, including with regard to the admissibility of evidence.Therefore, the Supreme Judicial Court of Massachusetts held that the consent provision of § 24 (1) (e) does not apply to violations under any other section or chapter, including G. L. c. 265, § 13 1/2, or G. L. c. 90, § 24L. The court affirmed the lower court's denial of Zucchino's motion to suppress his BAC results. View "Commonwealth v. Zucchino" on Justia Law

In this case, the Supreme Judicial Court of Massachusetts affirmed the lower court's summary judgment ruling against Jordan's Furniture, Inc. The company had implemented a commissions-based compensation scheme for its sales employees, which the plaintiff class argued failed to comply with the overtime and Sunday pay statutes as outlined in a previous case, Sullivan v. Sleepy's LLC. The court agreed, finding that Jordan's failed to provide separate and additional payments for overtime and Sundays, thereby violating the statutes. Furthermore, the court ruled that the Sunday pay statute can be enforced under the Wage Act's private right of action, as Sunday pay constitutes "wages earned" under the Wage Act. The court, however, vacated the award of attorney's fees to the plaintiff class and remanded the case to the lower court for recalculation of the award of attorney's fees, due to the lower court's reliance on common fund case law and categorical exclusion of time spent on settlement negotiations and mediation from the lodestar calculation. View "Sutton v. Jordan's Furniture, Inc." on Justia Law

Charles Robinson, the defendant, was convicted of first-degree murder in connection with the shooting death of Edward Figueroa. Following his conviction, Robinson appealed and also filed a motion for a new trial citing multiple errors by trial counsel. Despite his appeal and the motion for a new trial, the conviction was affirmed.Later, Robinson appealed from the denial of his motion for a new trial, arguing that he was not competent to stand trial due to mental health issues and that he had received ineffective assistance of counsel. However, the court upheld the ruling, stating that Robinson had not shown any evidence that his mental health issues had influenced the jury's conclusion or prevented an adequate defense.Robinson's contention that his counsel failed "reasonably to communicate with him" during and after a conversation in the lockup was also dismissed, as the court found no evidence of a breakdown in the attorney-client relationship that warranted a new trial.The court concluded that the defendant did not present a substantial issue meriting an evidentiary hearing and dismissed his request for relief under G. L. c. 278, § 33E for a new trial. View "Commonwealth v. Robinson" on Justia Law

In this case, the defendant, Rigoberto Escobar, was found guilty of first-degree murder for the shooting death of Magno Sosa after a heated argument that escalated into a fistfight. The defendant appealed, arguing that his confession to police was improperly obtained because he was improperly Mirandized, coerced into confessing, and his rights to prompt arraignment and telephone use after arrest were violated. Moreover, the defendant contended that the trial judge made errors by denying his motion for a mistrial and failing to instruct the jury on voluntary and involuntary manslaughter. He also claimed that improper testimony by the Commonwealth's experts on fingerprint identification and forensic ballistics led to a substantial likelihood of a miscarriage of justice. Lastly, the defendant argued that his firearm convictions should be vacated according to a recent ruling in Commonwealth v. Guardado.The Supreme Judicial Court of Massachusetts affirmed the defendant's conviction of murder in the first degree. They concluded that the defendant's motion to suppress his confession was properly denied, his motion for a mistrial was rightly denied, and the trial judge did not err in declining to provide a jury instruction on involuntary manslaughter. However, the trial judge did err in declining to instruct the jury on voluntary manslaughter. Despite this, they found the defendant was not prejudiced by this decision due to the jury instructions as a whole and the lack of evidence supporting a finding of voluntary manslaughter.The court also affirmed that even if the expert testimony was improper, it did not create a substantial likelihood of a miscarriage of justice because the Commonwealth presented overwhelming evidence tying the defendant to the firearm and to the crime. However, the court vacated the defendant's firearm convictions and remanded for a new trial to give the Commonwealth the opportunity to prove that the defendant was not licensed to carry a firearm. View "Commonwealth v. Escobar" on Justia Law

This case involved defendant Julie A. Corey who was convicted of first-degree murder on the grounds of deliberate premeditation, extreme atrocity or cruelty, and felony-murder with the underlying felony of aggravated kidnapping. Following her conviction, Corey filed a motion for a new trial, arguing that she received ineffective assistance of counsel due to her attorney's failure to call a cell phone expert to testify about her location on the night of the murder. She also requested that the court enter a required finding of not guilty. The trial judge, who was also the motion judge, denied Corey's motion for a new trial but vacated her conviction of murder in the first degree on a theory of felony-murder, finding that the evidence was insufficient to prove that Corey committed the predicate felony of aggravated kidnapping.On appeal, the Supreme Judicial Court disagreed with Corey’s argument that she received ineffective assistance of counsel. The court found that her trial counsel's decision not to call a cell phone expert was not ineffective and would not have likely influenced the jury's conclusions. Furthermore, the court agreed with the Commonwealth that there was sufficient evidence to find Corey guilty of felony-murder with a predicate felony of aggravated kidnapping. Consequently, the court reinstated that conviction. The court also declined to exercise its powers under G. L. c. 278, § 33E to reduce Corey's conviction. View "Commonwealth v. Corey" on Justia Law

In a dispute between tenured faculty members and Tufts University, the faculty members alleged that the university's policies requiring them to cover half of their salary with external research funding and reducing their laboratory space violated their tenure rights to economic security and academic freedom. These policies, instituted between 2016 and 2019, led to a decrease in the plaintiffs' salaries and full-time status, and their laboratory space was reduced or closed entirely when they failed to meet the external funding requirements.The Supreme Judicial Court of Massachusetts noted that tenure contracts are defined by their specific terms and must be understood in the context of the academic community's norms and expectations. The court found that the term "economic security" in the tenure contracts was ambiguous and further evidence was needed to determine whether the reductions in salary and full-time status violated the economic security provided in the tenure contracts. However, the court concluded that neither economic security nor academic freedom guaranteed the plaintiffs specific lab space.The court reversed the lower court's judgment in favor of Tufts on the compensation policies, remanding the case for further proceedings. However, it affirmed the lower court's judgment that the laboratory space guidelines did not violate the plaintiffs' tenure rights. The court also left unresolved the plaintiffs' claims under the Wage Act, as it was dependent on the outcome of the compensation dispute. View "Wortis v. Trustees of Tufts College" on Justia Law