Justia Massachusetts Supreme Court Opinion Summaries

This action arose from the Department of Environmental Protection's (Department) issuance of a waterways license under Mass. Gen. Laws ch. 91 (chapter 91 license) to the Boston Redevelopment Authority (BRA) to redevelop a section of land owned by the BRA on the seaward end of Long Wharf (project site). Plaintiffs, ten residents of Boston's North End neighborhood, appealed the issuance of the chapter 91 license, claiming the Department acted unconstitutionally and beyond its statutory authority when it issued the license without obtaining two-thirds vote of the Legislature as required by article 97 of the amendments to the Massachusetts Constitution. After the a Department's office of appeals affirmed the issuance of the license, the superior court ordered declaratory relief and issued a writ of mandamus ordering the Department to enforce article 97. The Supreme Court reversed, holding that article 97 did not apply to the project site, and therefore, a two-thirds vote of the Legislature was not required to approve the planned development. Remanded. View "Mahajan v. Dep't of Envtl. Prot." on Justia Law

After a jury trial, Defendant was convicted of carrying a firearm without a license based on a theory of constructive possession. Defendant appealed, contending, among other things, that the Commonwealth failed to present sufficient evidence to establish as a matter of law that Defendant had knowledge of the firearm's presence in his vehicle, the ability to exercise control over the weapon, and the intent to do so. The Supreme Court reversed Defendant's conviction and directed that a verdict of not guilty be entered, holding that although the evidence proffered by the Commonwealth was adequate to establish that Defendant knew the firearm was present in the motor vehicle he was operating and that he had the ability to exercise control over the weapon, the evidence was insufficient to prove Defendant had the requisite intention to control the firearm. View "Commonwealth v. Romero" on Justia Law

Defendant was indicted on drug-related charges that included trafficking in cocaine over twenty-eight grams. During the trial, certificates of chemical analysis establishing the weight and identity of the substance alleged to have been in Defendant's possession (drug certificates) were admitted into evidence. Defendant was convicted of the charges. After Defendant appealed, the U.S. Supreme Court issued its decision in Melendez-Diaz v. Massachusetts, which held that a drug analyst's certificate is testimonial and cannot be admitted at trial unless a defendant has the opportunity to cross-examine the analyst. Defendant then filed a motion for a new trial, arguing that the admission of the drug certificates violated his right to confrontation. The judge denied the motion, concluding that admission of the drug certificates was harmless beyond a reasonable doubt. The Supreme Court vacated Defendant's convictions and remanded the case for a new trial, holding that the erroneous admission of the drug certificates was not harmless beyond a reasonable doubt. View "Commonwealth v. Montoya" on Justia Law

Defendant was convicted of the deliberately premeditated murder of his wife. The Massachusetts Supreme Court affirmed, but the U.S. Supreme Court vacated the judgment and remanded the case in light of the recent U.S. Supreme Court decision in Williams v. Illinois, which addressed the admissibility under the Confrontation Clause of expert testimony about the results of DNA testing performed by non-testifying analysts. On remand, the Court reconsidered of the admissibility of testimony of an expert witness regarding DNA testing where the witness did not prepare the underlying data. The Supreme Court affirmed, holding (1) the Court's rules of evidence and the protections they afford are not inconsistent with Williams; (2) the witness's expert opinion that Defendant's DNA matched the DNA on items recovered from the crime scene was properly admitted; and (3) the witness's direct testimony to the details of the DNA test results of a nontestifying analyst was improperly admitted, but Defendant was not prejudiced by the erroneous admission. View "Commonwealth v. Greineder" on Justia Law

Construction Company contracted with Subcontractor for construction of elements of an HVAC system. As partial collateral for a revolving line of credit, Subcontractor assigned to Bank its right to receive payment under the contract with Construction Company. Construction Company instead made twelve payments to Subcontractor. Subcontractor subsequently ceased business operations, leaving an outstanding debt to Bank on its line of credit. Bank filed an action against Construction Company for breach of contract and violation of the UCC. A jury found (1) Construction Company liable on both counts for ten of the twelve checks that it had delivered to Subcontractor, and (2) Bank was estopped from recovering with respect to the final two checks. The judge entered judgment on the statutory claim in the amount of $3,015,000, the full face value of the ten checks. The Supreme Court affirmed in part and reversed in part, holding that the trial judge (1) properly entered judgment on Bank's statutory claim in the amount of the wrongfully midirected payments; but (2) erred in denying the bank's motion for partial judgment notwithstanding the verdict with respect to the final two checks, as there was insufficient evidence to support Construction Company's defense of estoppel. View "Reading Coop. Bank v. Constr. Co." on Justia Law

Plaintiff, HipSaver, Inc., was a Massachusetts corporation engaged in the design, manufacture, and sale of hip protectors. In 2007, the Journal of the American Medical Association (JAMA) published an article authored in part by Defendant, an associate professor at Harvard Medical School, that concluded based on the results of a clinical trial that hip protectors were "not effective in nursing home populations." HipSaver filed a complaint against Defendant, claiming that Defendant had disparaged HipSaver's product in the JAMA article and was liable for monetary damages. The trial judge granted Defendant's motion for summary judgment and dismissed HipSaver's complaint. The Supreme Court affirmed, holding that summary judgment was properly entered for Defendant where HipSaver failed to demonstrate that it had a reasonable expectation of proving all of the essential elements of a cause of action for commercial disparagement. View "HipSaver, Inc. v. Kiel" on Justia Law

Father of a sixteen-year-old daughter filed a complaint for protection under Mass. Gen. Laws ch. 209A against Defendant, a twenty-four-year-old man, seeking to prevent his daughter from voluntarily engaging in a sexual relationship with Defendant. Defendant was served with the ex parte abuse prevention order. Following a hearing before a district court judge, the order was extended for one year. Defendant appealed, asserting that the evidence was insufficient to support a finding of abuse and that the order should not have been extended because he and Plaintiff were not in a substantive dating relationship. The Supreme Court vacated the extension order, holding that there was no basis for the judge to conclude that Defendant's conduct rose to the level of "abuse" as required by the statute. View "E.C.O. v. Compton" on Justia Law

Mother and Father were divorced by a judgment of divorce dated 2008 that granted shared legal custody of the parties' child and physical custody to Mother. The judgment included an order directing Father to pay child support to Mother. In 2009, Mother filed a complaint for modification of the child support order, claiming that Father's promotion and increased salary had changed the circumstances underlying the original support order. The trial judge dismissed the modification complaint, finding that the increase in Father's income was not a material and substantial change of circumstances and that no modification was warranted. The appeals court affirmed. The Supreme Court reversed, concluding that the trial judge erred in applying a standard requiring a material and substantial change in circumstances rather than the standard set forth in Mass. Gen. Laws ch. 208, 28, which provides that a child support order shall be modified if there is an inconsistency between the amount of the existing order and the amount that would result from application of the Massachusetts Child Support Guidelines. Remanded for consideration of the modification request under the statutory inconsistency standard. View "Morales v. Morales" on Justia Law

Employees of Michaels Stores, Inc. request and record customers' zip codes in processing credit card transactions. Plaintiff, a customer of Michaels, filed an action on behalf of herself and a putative class of Michaels customers in the federal district court, alleging that Michaels unlawfully writes customers' personal identification information on credit card transaction forms in violation of Mass. Gen. Laws ch. 93, 105(a) (the statute). The Supreme Court accepted certification to answer questions of state law and held (1) a zip code constitutes personal identification information for purposes of the statute; (2) a plaintiff may bring an action for violation of the statute absent identity fraud; and (3) the term "credit card transaction form" in the statute refers equally to electronic and paper transaction forms. View "Tyler v. Michael Stores, Inc." on Justia Law

Premier Capital, LLC was in the business of debt acquisition, management, and collection. On July 3, 2007, Premier filed an action in the superior court alleging that it was the current holder of a sealed promissory note from Max Zeller Furs, Inc., executed on September 10, 1987, and that KMZ, Inc. was liable on the note as the successor in interest. The superior court granted summary judgment for KMZ on the ground that Premier's complaint was not timely filed under the six-year statute of limitations set forth in Mass. Gen. Laws ch. 106, 3-118. The Supreme Court reversed, holding (1) although the statute does apply to actions on a sealed promissory note, it only applies to causes of action accruing after its enactment in 1998; and (2) because Premier's cause of action accrued before the statute was enacted, and the note upon which Premier filed suit was executed under seal, Premier timely commenced its action against KMZ under the twenty-year statute of limitations governing actions on contracts under seal set forth in Mass. Gen. Laws ch. 260, 1. Remanded. View "Premier Capital, LLC v. KMZ, Inc." on Justia Law