Justia Massachusetts Supreme Court Opinion Summaries

Luis Alicea pleaded guilty to a firearm offense and was sentenced to three and one-half years' incarceration. Alicea later filed suit in federal court against his former defense counsel, Lawrence McGuire, alleging that McGuire's conduct resulted in Alicea's serving an illegal sentence. The district court judge granted summary judgment for McGuire. While the federal case was pending, Alicea filed an action in the superior court against the Commonwealth as McGuire's employer, asserting claims of malpractice and negligent infliction of emotional distress. Alicea's claims were premised on the allegation that McGuire had caused Alicea to serve an illegal sentence. The superior court granted summary judgment for the Commonwealth, concluding that the judgment entered in the federal action precluded Alicea from litigating the issue of his purported illegal sentence. The Supreme Court affirmed, holding that because the central issue of Alicea's claims in the superior court was decided in the federal action, application of the doctrine of issue preclusion prevented Alicea from relitigating the issue. View "Alicea v. Commonwealth" on Justia Law

Claimant sustained injuries in a car accident. The car was insured under a standard Massachusetts automobile insurance policy (auto policy) issued by Liberty Mutual that included optional "medical payments" coverage (MedPay). Claimant was also insured under a separate policy of health insurance issued by Blue Cross Blue Shield (Blue Cross). Liberty Mutual paid personal injury protection benefits to Claimant and Claimant's additional medical expenses. After Liberty Mutual declined to pay Claimant any MedPay benefits because Blue Cross had already submitted the expenses, Claimant commenced this action against Liberty Mutual on behalf of herself and a putative class of similarly situated individuals. On remand, the superior court granted Liberty Mutual's motion for judgment on the pleadings. The Supreme Court reversed, holding that Claimant was entitled to the MedPay benefits provided by her auto insurance policy, notwithstanding that her medical expenses were covered by and paid under a separate policy of health insurance. Remanded. View "Golchin v. Liberty Mut. Ins. Co." on Justia Law

Defendant, a New Hampshire resident, was issued a temporary nonresident unrestricted license to carry firearms in Massachusetts. After Defendant alarmed employees at a medical office during his medical appointment by informing them he was armed, the firearms records bureau revoked Defendant's license, determining that he was no longer a "suitable person" to possess a firearm in Massachusetts. The district court ordered that Defendant's license be reinstated, but the superior court reversed. The Supreme Court reversed, holding (1) the "suitable person" requirement set forth in Mass. Gen. Laws ch. 140, 131 applies to temporary nonresident licenses issued pursuant to Mass. Gen. Laws. ch. 140, 131F; but (2) in the absence of regulations further defining unsuitability, no reasonable ground existed to revoke Defendant's license. Remanded. View "Firearms Records Bureau v. Simkin" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder. The Supreme Court affirmed, holding (1) trial counsel was not ineffective in preparing and presenting Defendant's motion to suppress his statement to police, and any error on the part of the motion judge in denying Defendant's motion was not likely to have affected the jury's conclusion; (2) the trial judge did not violate Defendant's right to a public trial by closing the court room during a witness immunity hearing; (3) the trial judge did not err in instructing the jury on the Commonwealth's burden of proof; and (4) there was insufficient evidence to support Defendant's conviction on the theory of felony-murder, but the evidence was sufficient to support the jury's conclusion that Defendant killed the victim with deliberate premeditation and extreme atrocity or cruelty. View "Commonwealth v. Mercado" on Justia Law

Defendants were indicted on charges of armed robbery and other crimes in conjunction with the robbery of a gasoline station. The Commonwealth sought a buccal swab from each defendant for purposes of DNA testing of a firearm used in the robbery and a necklace allegedly taken from a victim of the robbery. The superior court judge ordered both defendants to provide buccal swabs. A single justice of the Supreme Court treated Defendants' respective appeals as petitions brought under Mass. Gen. Laws ch. 211, 3 and denied Defendants' petitions for relief. The Supreme Court affirmed, holding (1) a petition under chapter 211, section 3 was the appropriate means by which to seek interlocutory relief from the court orders compelling Defendants to provide a buccal swab; and (2) under the circumstances, the single justice properly denied Defendants' petitions. View "Commonwealth v. Bertini" on Justia Law

Plaintiffs brought a medical malpractice action against a number of defendants, including Physician. After the medical malpractice tribunal determined there was not sufficient evidence to raise a legitimate question of Physician's liability appropriate for judicial inquiry, Plaintiffs moved for a reduction of the $6,000 bond they were required to file to continue to pursue their claim. The judge concluded that Plaintiffs were indigent. However, because the judge believed Plaintiffs' attorney was funding the expenses of litigation, including the cost of the bond, the judge refused to reduce the amount of the bond. The Supreme Court vacated the denial of Plaintiffs' motion to reduce the amount of the bond, holding that a judge cannot consider the potential resources of counsel in determining whether to reduce the bond amount under Mass. Gen. Laws ch. 231, 60B. Remanded. View "Faircloth v. DiLillo" on Justia Law

Plaintiffs brought a medical malpractice action against a number of defendants, including Physician. A medical malpractice tribunal determined that there was not sufficient evidence to support a finding of liability as to Physician. Plaintiffs were informed they had to provide a $6,000 bond to avoid dismissal of the claim pursuant to Mass. Gen. Laws ch. 231, 60B. Plaintiffs subsequently filed an emergency motion to reduce the amount of the bond, asserting that they were indigent and that failing to lower the bond amount would result in the dismissal of the case against Physician. The judge found Plaintiffs were indigent but denied the motion because he believed Plaintiffs' attorney was paying for Plaintiffs' litigation expenses. The Supreme Court vacated the denial of Plaintiffs' emergency motion and remanded, holding that, in denying Plaintiffs' motion without evaluating Plaintiffs' effort to present a sufficient offer of proof at the tribunal or the reasonableness of Plaintiffs' continued pursuit of their claim, the judge based his ruling on a legally erroneous standard and therefore abused his discretion. View "Cruz v. Siddiqi" on Justia Law

After a jury trial, Defendant was convicted of possession with intent to distribute a class B controlled substance in connection with the death of Richard Beaulier. During trial, a toxicologist testifying as an expert witness for the Commonwealth testified about the results of laboratory testing and toxicological analysis of Beaulier's blood, which showed the presence of a high level of fentanyl. The toxicologist, however, had not conducted any of the testing. The appeals court affirmed the conviction, holding that the admission of the toxicology results testing conducted by a nontestifying analyst constituted constitutional error, but the error was harmless beyond a reasonable doubt. The Supreme Court affirmed, holding that the improperly admitted evidence would have had little or no effect on the fact finder, and therefore the error was harmless beyond a reasonable doubt. View "Commonwealth v. Lezynski" on Justia Law

In Feeney II, the Massachusetts Supreme Court affirmed the ruling of the superior court invalidating a class action waiver in the parties' arbitration agreement, holding that the Federal Arbitration Act (FAA) does not foreclose a court from invalidating an arbitration agreement that includes a class action waiver if it effectively denies the plaintiffs a remedy. The U.S. Supreme Court subsequently issued an opinion in American Express Co. v. Italian Colors Restaurant (Amex) holding that a class action waiver in an arbitration agreement is enforceable under the FAA even if a plaintiff proves that the class waiver effectively precludes the plaintiff from vindicating his federal statutory rights. The Massachusetts Supreme Court subsequently concluded that following Amex, the Court's analysis in Feeney II no longer comported with the U.S. Supreme Court's interpretation of the FAA, holding instead that a class waiver may not be invalidated on the grounds that it effectively denies the plaintiffs a remedy. Remanded. View "Feeney v. Dell Inc. " on Justia Law