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Justia Massachusetts Supreme Court Opinion Summaries
Dacey v. Burgess
The Supreme Judicial Court affirmed the housing court's entry of judgment in favor of Landlord in this landlord-tenant dispute and the denial of Tenant's motion to revise, revoke, or vacate that judgment, holding that Landlord could seek to enforce the parties' voluntary stipulation following mediation and attempt to recover possession of the leased premises.Following mediation in early 2020, Tenant entered into a stipulation to voluntarily dismiss all claims against Landlord. Tenant further agreed to vacate Landlord's apartment. Because of an emergency eviction moratorium imposed pursuant to COVID-19, Landlord was unable to seek judgment on the stipulation and execution on such judgment until October 2020. The housing court judge entered judgment in favor of Landlord. Tenant filed a motion to revise, revoke, or vacate the judgment, which the housing court denied. The Supreme Court affirmed, holding that the judge had the authority to award possession of the premises to Landlord under the circumstances of this case. View "Dacey v. Burgess" on Justia Law
Posted in:
Landlord - Tenant
Papp v. Commonwealth
The Supreme Judicial Court dismissed Appellant's appeal from a judgment of the county court denying, without a hearing, Appellant's petition for extraordinary relief under Mass. Gen. Laws ch. 211, 3, holding that the appeal was moot.During Appellant's criminal trial, the prosecutor experienced a medical problem requiring that he be immediately treated at a hospital. Consequently, the judge declared a mistrial and ruled that a retrial was permissible. Appellant filed a petition under Mass. Gen. Laws ch. 211, 3, arguing that there was no manifest necessity for the mistrial and that retrial would violate his constitutional protections against double jeopardy. The single justice denied relief. Thereafter, a second jury trial was held, and Appellant was convicted as charged. The Supreme Judicial Court dismissed Appellant's appeal from the denial of his Mass. Gen. Laws ch. 211, 3 petition, holding that, because Appellant's retrial had already taken place, the appeal was moot. View "Papp v. Commonwealth" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Ronchi
The Supreme Court affirmed Defendant's convictions of two counts of murder in the first degree, holding that this Court's precedent on reasonable provocation based on sudden oral revelations of infidelity, and, relatedly, lack of paternity, is hereby disavowed.Defendant stabbed his girlfriend, who was nine months pregnant, killing her and her viable fetus. At issue at trial was whether the stabbing had been mitigated by "heat of passion upon reasonable provocation," thus reducing Defendant's liability to manslaughter, because his girlfriend falsely disclosed that he was not the father. The Supreme Court affirmed, holding (1) rational jurors could have found that the stabbings were not the result of a heat of passion upon reasonable provocation, and therefore, the evidence was sufficient to support Defendant's convictions; and (2) this Court no longer recognizes that an oral discovery of infidelity satisfies the objective element of something that would provoke a reasonable person to kill his or her spouse. View "Commonwealth v. Ronchi" on Justia Law
Posted in:
Criminal Law
Velazquez v. Commonwealth
The Supreme Judicial Court held that the presumptive ninety-day time limit on pretrial detention set forth in Mass. Gen. Laws ch. 276, 58B begins to run at the time an individual is detained, regardless of whether a formal order of detention has entered.At issue in this case was whether the presumptive time limit on pretrial detention outlined in section 58B is calculated from when an individual is first detained or from when the order of detention formally issues. Defendant asked that the docket be corrected in his dismissed case to reflect that his ninety days of detention pursuant to section 58B began to run on the date of arraignment rather than the date that the formal order of detention issued. The request was denied. Defendant then brought this petition under Mass. Gen. Laws ch. 211, 3 seeking extraordinary relief. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that, where section 58B is applicable, the ninety-day clock begins to run at the time a person is detained and his or her liberty is curtailed, not when the formal order is issued. View "Velazquez v. Commonwealth" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Ng
The Supreme Court affirmed Defendant's conviction of murder in the first degree on a theory of deliberate premeditation and declined to exercise its authority under Mass. Gen. Laws ch. 33E either to reduce the verdict or to grant Defendant a new trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) Defendant's absence from substantive sidebar conferences was error on the part of the trial court, but the error was harmless; (2) the trial judge did not abuse his discretion in ruling that a challenged statement was inadmissible hearsay and failed to satisfy one of the exceptions to the hearsay rule; (3) the trial judge did not abuse his discretion in admitting expert testimony on Defendant's military record; (4) the closure of the courtroom during jury selection did not violate Defendant's constitutional right to a public trial; (5) Defendant received effective assistance of counsel; and (6) there was no reason for the Court to exercise its discretion to reduce Defendant's conviction to murder in the second degree. View "Commonwealth v. Ng" on Justia Law
Posted in:
Criminal Law
Huang v. Ma
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
Posted in:
Contracts, Real Estate & Property Law
Executive Office of Health & Human Services v. Mondor
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
Dermody v. Executive Office of Health & Human Services
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
Commonwealth v. Eagles
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
Davis v. Commonwealth
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