Justia Massachusetts Supreme Court Opinion Summaries

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The Supreme Judicial Court dismissed as moot Plaintiffs' appeal arguing that the Department of Correction (DOC) illegally kept them in custody after a final decision on their petitions for medical parole had been made by the Commissioner of Correction but answered two questions reported by the single justice.Plaintiffs were two prisoners recently released under the medical parole statute. Before their actual release from incarceration, Plaintiffs sought relief from a single justice of the court. The single justice denied Plaintiffs' request for relief and separately reported two questions to the Supreme Judicial Court regarding the requirements of finding a replacement for a prisoner who is granted medical parole and the timing of a prisoner's release after medical parole is granted. The Supreme Judicial Court dismissed Plaintiffs' appeal as moot and answered (1) after medical parole is granted the DOC must develop comprehensive plans including a proposed course and site for treatment; and (2) once a favorable decision by the Commissioner allows release on medical parole, the DOC must be proactive in working to release the prisoner expeditiously. View "Malloy v. Department of Correction" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the single justice of the court affirming the decision of the Board of Registration in Medicine revoking Joseph Knight's inchoate right to renew his medical license, holding that the Board's decision was amply supported by the evidence and that Knight failed to demonstrate prejudice from any alleged legal or procedural defect.During his career as a physician, Knight was licensed to practice medicine in multiple jurisdictions in the United States. After receiving complaints about his prescription practices, Knight applied for a second renewal of his Massachusetts license. On his application, Knight admitted that he had been the subject of a disciplinary action but denied other allegations. The Board then issued a statement of allegations against Knight, and the disciplinary proceedings proceeded. The Supreme Judicial Court affirmed, holding that there was no doubt that the Board was justified in reach the result it did. View "Knight v. Board of Registration in Medicine" on Justia Law

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The Supreme Judicial Court answered three reported questions regarding judicial proceedings stemming from the denial of a petition for medical parole.Plaintiffs - Raymon Harmon and Brian Racine - were prisoners who applied for release under Mass. Gen. Laws ch. 127, 119A, the medical parole statute. The Commissioner of Correction denied both petitions. Harmon sought judicial review but died while his case was pending in the superior court. Racine requested that the Commissioner reconsider her decision and died after the Commissioner denied the request. The Supreme Judicial Court held (1) a prisoner's death renders judicial proceedings stemming from the denial of a petition for medical parole moot, but a court may use its discretion to decide the case; (2) the regulations of the Department of Corrections that limit the ability of prisoners to submit subsequent petitions for medical parole after one has been denied or not acted upon are void; and (3) section 119A applies only to committed offenders serving a sentence and not to pretrial detainees. View "Harmon v. Commissioner of Correction" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court reversed Defendant's convictions of armed assault with intent to murder and related charges, holding that the trial judge erred in admitting evidence obtained from a global positioning system (GPS) device that Defendant was wearing at the time of the crime.Due to his probation on a federal drug charge, Defendant was wearing a GPS ankle monitor on the night of the shooting at issue. During trial, the court admitted data from Defendant's GPS device showing his location at the time of the shooting and that his speed matched the shooter's movements. The Supreme Judicial Court reversed Defendant's convictions, holding that because the GPS device Defendant was wearing had never been formally tested for its ability to measure speed, the trial judge abused his discretion in admitting the speed evidence. View "Commonwealth v. Davis" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of both deliberate premeditation and extreme atrocity or cruelty, holding that there was no reversible error either in any issue raised by Defendant or in this Court's review under Mass. Gen. Laws ch. 33E.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress handwritten note and oral statements he made to officers while he was hospitalized; (2) Defendant was not entitled to reversal of his convictions on the grounds of error in the trial judge's evidentiary rulings; (3) the trial judge did not err in denying Defendant's motion for a new trial; and (4) there was no basis for reducing Defendant's sentence on the murder conviction or ordering a new trial. View "Commonwealth v. Welch" on Justia Law

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The Supreme Judicial Court affirmed the judgment of a judge of the superior court dismissing Relator's claims alleging that Defendants collectively engaged in and conspired to engage in fraud, holding that this suit was subject to the public disclosure bar of the Massachusetts False Claims Act (MFCA), Mass. Gen. Laws ch. 12, 5A-50.The MCFA contains a public disclosure bar that generally requires that an action be dismissed if substantially the same allegations or transactions as alleged have previously been disclosed through certain enumerated sources. Relator commenced this action on behalf of the Commonwealth against certain financial institutions and their subsidiaries. Defendants argued that dismissal was required pursuant to the MFCA's public disclosure bar because the subject transactions had previously been disclosed to the public through news media and Relator was not an original source of the information concerning the fraud. The superior court dismissed the complaint. The Supreme Judicial Court affirmed, holding that the superior court correctly dismissed Relator's claims. View "Rosenberg v. JPMorgan Chase & Co." on Justia Law

Posted in: Banking
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The Supreme Judicial Court affirmed the judgment of a judge of the probate court denying Appellant's special motion to dismiss the amended objection of William Charles Hamm, a protected person, to a conservator's final account, holding that the anti-SLAPP statute, Mass. Gen. Laws ch. 231, 59H, did not apply in this circumstance.The conservator filed accounts for each of the seventeen years for which she and her husband were conservators for their son, the protected person in this case. The protected person filed an objection and amended objection to the final accountings. The conservator objected with two motions to dismiss, including the anti-SLAPP motion at issue on appeal. The probate court judge denied both motions. The Supreme Judicial Court affirmed, holding that the anti-SLAPP statute did not apply in the circumstances of this case. View "In re Hamm" on Justia Law

Posted in: Health Law
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The Supreme Judicial Court affirmed the allowance of Defendant's motion for a new trial, holding that the evidence supporting the charge of armed home invasion was insufficient to allow a finding beyond a reasonable doubt on each element of the offense.Defendant was convicted of armed home invasion, armed burglary, robbery while armed and masked, and other charges. Defendant later filed a motion for a new trial on the charge of armed home invasion, arguing that there was insufficient evidence that he was armed when he entered the building. The superior court allowed the motion. The Supreme Judicial Court affirmed and vacated and set aside Defendant's conviction of armed home invasion, holding that because there was no evidence that Defendant armed himself with a weapon before he entered the building, he could not be convicted of armed home invasion. The Court remanded the matter to the superior court for reconsideration of the sentencing scheme on the remaining convictions. View "Commonwealth v. Tinsley" on Justia Law

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The Supreme Court reversed the order of the superior court denying Defendant's motion for a new trial and vacated Defendant's conviction of aggravated rape, holding that Defendant was entitled to a new trial.Defendant was convicted of aggravated ripe of a child under the age of fourteen years. Defendant later filed a third motion for new trial, arguing that his defense was prejudiced by the Commonwealth's failure to disclose exculpatory evidence concerning a key witness. The Supreme Court reversed Defendant's conviction and remanded the case to the superior court for a new trial, holding (1) the undisclosed evidence was exculpatory; and (2) Defendant was prejudiced by the nondisclosure of the prosecutor's note. View "Commonwealth v. Caldwell" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court reversed the order of the trial judge denying Defendant's motion to continue his evidentiary hearing on his motion to suppress until it could be held in person, holding that the trial judge abused her discretion.Defendant, who was charged with a drug offense, filed a motion to suppress evidence and statements. After the suppression hearing was postponed for a third time because of the COVID-19 pandemic the judge ordered that the hearing take place via Zoom. Defendant filed a motion objecting to the Zoom hearing and requested that the case be continued until an in-court hearing could be held safely. The judge denied the motion. The Supreme Judicial Court reversed, holding that because Defendant waived his right to a speedy trial and there were no civilian victims or witnesses, the trial judge abused her discretion in denying Defendant's objection to conducting the evidentiary hearing on his motion to suppress via Zoom video conference. View "Diaz v. Commonwealth" on Justia Law