In this case, the plaintiff, Fallon Community Health Plan, Inc., adopted a policy requiring its employees to be vaccinated against COVID-19. The defendant, Shanika Jefferson, a home health aide employed by Fallon, sought a religious exemption from the vaccination requirement. Her request was denied, and her employment was terminated. Jefferson then applied for and was approved for unemployment benefits from the Department of Unemployment Assistance. However, Fallon contended that Jefferson was ineligible for the benefits and sought review of the decision. The board of review of the department, as well as a District Court judge, affirmed the decision.Fallon argued that Jefferson was disqualified from receiving unemployment benefits as per § 25 (e) (2) of General Laws c. 151A because she refused the COVID-19 vaccine in knowing violation of Fallon's reasonable policy and in wilful disregard of Fallon's interest in keeping its vulnerable patient population healthy. However, the Supreme Judicial Court disagreed with Fallon's contention. The court held that Jefferson did not engage in "deliberate misconduct", but rather made a good faith effort to comply with Fallon's policy by applying for a religious exemption. The court also found that Fallon failed to demonstrate that Jefferson should be disqualified on the basis of a "knowing violation" of that policy. The court considered the unique circumstances of the case, including Jefferson's sincere religious beliefs, which did not present her with a meaningful choice regarding vaccination. Therefore, the Supreme Judicial Court affirmed the decision of the lower courts, allowing Jefferson to receive unemployment benefits. View "Fallon Community Health Plan, Inc. v. Acting Director of the Department of Unemployment Assistance" on Justia Law

The dispute arose from an agreement between Columbia Plaza Associates (CPA) and Northeastern University regarding the development of a parcel of land in Boston. The contract stipulated that the developer for each phase of the project would be Northeastern or an affiliated entity, which could include CPA. The contract also specified that the developer of the garage parcel would be a joint venture between Northeastern and CPA.CPA claimed that Northeastern violated the agreement when it sought to develop a subparcel unilaterally and repudiated CPA's rights to that subparcel. CPA also argued that Northeastern's communication with a governmental agency amounted to a deceptive business practice.The court held that the agreement did not grant CPA development rights in any of the subparcels except for the garage parcel. The court also found no proof of an enforceable promise by Northeastern to build a hotel with CPA on the disputed subparcel. The court thus ruled in favor of Northeastern on all counts, including CPA's claims for breach of contract, breach of the implied covenant of good faith and fair dealing, intentional interference with advantageous economic relations, unjust enrichment, commercial fraud, unfair or deceptive business practices, and requests for declaratory and injunctive relief.The court further held that Northeastern was entitled to attorney's fees under the anti-SLAPP statute because it successfully dismissed CPA's claim of commercial fraud, which was based solely on Northeastern's petitioning activity. The court did not find CPA's claim to be a SLAPP suit. View "Columbia Plaza Associates v. Northeastern University" on Justia Law

In a complex commercial dispute with a series of administrative and legal challenges, the Supreme Judicial Court of Massachusetts found that the defendants, Bristol Asphalt Co., Inc. and others, did not meet the criteria to dismiss the case under the "anti-SLAPP" statute. The court outlined a simplified framework for considering anti-SLAPP motions, returning to the traditional approach set out in Duracraft Corp. v. Holmes Prods. Corp. The court also clarified that the appropriate standard of review for a ruling on a special motion to dismiss is de novo, rather than for an abuse of discretion.The dispute arose from the plaintiffs' efforts to open an asphalt plant in the same industrial zone as the existing plant owned by the defendants. The defendants launched a series of administrative and legal challenges to the plaintiffs’ efforts to obtain regulatory approval for the construction and operation of the proposed plant. The plaintiffs filed a three-count complaint alleging that the defendants' legal challenges constituted unfair or deceptive acts or practices, conspiracy in restraint of trade, and abuse of process. In response, the defendants filed a special motion to dismiss under the anti-SLAPP statute.The Supreme Judicial Court affirmed the lower court's denial of the defendants' special motion to dismiss, concluding that the defendants' petitioning activities were not entitled to the procedural protections of the anti-SLAPP statute. The court found that the defendants' challenges to the plaintiffs' proposed asphalt plant did not lack any reasonable factual support or arguable legal basis. Therefore, the plaintiffs' claims against the defendants were not based solely on the defendants' petitioning activities and were not subject to dismissal under the anti-SLAPP statute. View "Bristol Asphalt, Co., Inc. v. Rochester Bituminous Products, Inc." on Justia Law

In the case of Commonwealth v. Rashad Shepherd, the Supreme Judicial Court of Massachusetts affirmed the defendant’s conviction of murder in the first degree on the theory of felony-murder, with attempted unarmed robbery as the predicate felony. The case centered around a failed robbery attempt that ended in the shooting and death of the intended victim. The defendant, along with two co-conspirators, hatched a plan to rob the victim, who was known to sell marijuana from his apartment. However, when the plan was put into motion, the victim resisted, and in the ensuing altercation, was shot and killed. The prosecution's theory was that the defendant was the shooter.In his appeal, the defendant argued that the court’s decision in a prior case, Commonwealth v. Brown, which abolished felony-murder as an independent theory of liability for murder in the first and second degrees, should be applied to his case retroactively. He maintained that not doing so violated equal protection principles as more Black individuals were serving life sentences without parole for felony-murder than white individuals. However, the court rejected this argument, noting that the decision in Brown was applied to all equally, regardless of race or ethnicity.The defendant also claimed errors in jury instructions and conduct by the trial judge, but the court determined that there was no reversible error. Lastly, the defendant argued that he received ineffective assistance of counsel, but the court found that the decisions by the defense were not manifestly unreasonable. View "Commonwealth v. Shepherd" on Justia Law

In the case before the Supreme Judicial Court of Massachusetts, the defendant, William J. Camuti, was convicted of murder in the first degree for poisoning his friend and business associate, Stephen Rakes, with potassium cyanide. Several years after his conviction, Camuti filed a postconviction motion for forensic testing of the shirt that Rakes was wearing when his body was found, claiming that DNA testing of the shirt could potentially provide evidence that could exonerate him. However, a Superior Court judge denied the motion, finding that Camuti had failed to meet his burden under G. L. c. 278A, § 7 (b), to demonstrate that a reasonably effective defense attorney would have sought to test Rakes' shirt for DNA.On appeal, the Supreme Judicial Court affirmed the lower court's decision. The court reasoned that the absence of trace evidence, including DNA evidence, was a central part of Camuti's defense strategy at trial. His counsel had repeatedly emphasized the lack of physical evidence linking Camuti to the crime scene, and the introduction of DNA evidence from Rakes' shirt could have undermined this defense. The court further noted that even if DNA testing had revealed the presence of a third party's DNA on the shirt, this would have had minimal exculpatory value given the circumstances of the case. Given these considerations, the court concluded that a reasonably effective attorney would not have sought DNA testing of Rakes' shirt. Therefore, Camuti had not met his burden under G. L. c. 278A, § 7 (b), and the denial of his postconviction motion for forensic testing was affirmed. View "Commonwealth v. Camuti" on Justia Law

The case involves the Commonwealth's appeal against the trial judge's denial of its motion to admit expert testimony on Frequent Location History (FLH) data retrieved from the defendant's cell phone in a murder case. The Commonwealth argued that the FLH data would corroborate its witness's testimony, placing the defendant at the crime scene. The trial judge denied the motion, stating that the Commonwealth had not met its burden of showing that FLH data had been generally accepted as reliable by the scientific community. The judge also found that the Commonwealth had failed to provide evidence that FLH data has been subjected to peer review or publication, has an unacceptably high known or potential rate of error, and is governed by recognized standards. The Supreme Judicial Court for the county of Suffolk agreed with the trial judge's decision, concluding that the Commonwealth had not shown that FLH data is reliable. Therefore, the court affirmed the trial judge's denial of the Commonwealth's motion to admit the FLH data. View "Commonwealth v. Arrington" on Justia Law

In this case, the Supreme Judicial Court of Massachusetts was called upon to determine which law applied to the sealing of records from youthful offender proceedings - G. L. c. 276, § 100A, the adult criminal record sealing statute or G. L. c. 276, § 100B, the juvenile delinquency sealing statute. The case arose when the Commissioner of Probation denied the petitioner's request to have his youthful offender records sealed under § 100B and instead applied the adult criminal record sealing statute, § 100A.The court, after examining both statutes and considering the legislative intent, concluded that § 100B, the juvenile delinquency sealing statute, was the proper statute for the sealing of records of youthful offenders. The court found that the Legislature’s intent to aid, encourage, and guide juveniles, which includes youthful offenders, was more consistent with the process outlined in § 100B.The court held that it was an error for the Commissioner of Probation to refuse to seal the petitioner's Juvenile Court records under § 100B, as the petitioner had satisfied all the requirements under the statute. Therefore, the case was remanded back to the county court for the entry of a judgment in favor of the petitioner. View "In the Matter of an Impounded Case" on Justia Law

The case involves an appeal from a wrongful death action brought by Joni Babaletos, the personal representative of her late husband Thomas Babaletos, against Demoulas Super Markets, Inc., Philip Morris USA Inc., and R.J. Reynolds Tobacco Company. Babaletos claimed that the cigarettes produced and sold by the defendants caused her husband's death. She brought claims for breach of warranty in design, negligence in design and marketing, fraud, civil conspiracy, and unfair and deceptive acts and practices in violation of G. L. c. 93A, § 9. The jury found for the defendants on the four claims presented to them, and the trial judge subsequently found no liability with respect to the c. 93A claim.On appeal, Babaletos argued that the trial judge's imposition of time limits for the presentation of evidence forced her to omit essential evidence. The Supreme Judicial Court of Massachusetts held that Babaletos failed to demonstrate either an abuse of discretion by the trial judge or how she was prejudiced by the imposition of time limits. The court noted that the trial judge had repeatedly offered to extend scheduled half days to full days should the need arise during trial, but Babaletos made no such requests as the trial progressed. As such, the court affirmed the trial court's judgment. The court also provided guidance for trial judges who believe that setting time limits for the presentation of evidence would be prudent in a particular case. View "Babaletos v. Demoulas Super Markets, Inc." on Justia Law

In 1995, the bodies of a woman and her daughter were found in separate locations in Massachusetts and Connecticut. More than two decades later, the woman's husband was convicted for her murder. On appeal, he asserted that the evidence was insufficient to establish his identity and deliberate premeditation, and challenged the admissibility of his daughter's murder evidence, the testimony of two latent print examiners, and the limitation on introducing a potential third-party culprit.The Supreme Judicial Court of Massachusetts affirmed the conviction. The court found no reversible error in the trial court's decisions and determined that the evidence was sufficient for the jury to find that the husband was the perpetrator and committed the crime with deliberate premeditation. The court also ruled that the evidence of the daughter's murder was admissible to establish the identity of the perpetrator of the mother's murder. The court also found no issues with the testimony of the latent print examiners and did not find any unfair limitations on the defendant's ability to present evidence of a potential third-party culprit. Furthermore, the court ruled that the defendant's rights to confront witnesses were not violated by the testimony of the latent print examiners. Lastly, the court deemed that the defendant's argument on the degree of certainty expressed by the latent print examiners was unpreserved, and the error did not create a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Honsch" on Justia Law

The case concerns the constitutional rights of a criminal defendant, A.Z., who was involuntarily hospitalized for a competency determination under Massachusetts law, G. L. c. 123, § 15 (b). The Supreme Judicial Court of Massachusetts held that the involuntary commitment of a criminal defendant for a competency determination infringes upon a defendant's fundamental right to liberty and thus must satisfy strict scrutiny under the Massachusetts Declaration of Rights and the United States Constitution. To pass strict scrutiny, the involuntary commitment must be the least restrictive means available to vindicate the governmental interest at stake. Therefore, it is unconstitutional for a court to hospitalize a pretrial defendant for a clinical evaluation and observation of competency, absent a finding by the judge, by clear and convincing evidence, that hospitalization is the least restrictive means available to adequately determine a criminal defendant's competency to stand trial. The judge in this case did not make such findings, so the court concluded that the defendant's constitutional rights were violated. View "Commonwealth v. A.Z." on Justia Law