Justia Massachusetts Supreme Court Opinion Summaries

by
The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition for extraordinary relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused her discretion in denying relief.Petitioner primarily sought relief from a superior court judgment revoking his probation and imposing a suspended sentence. In his petition, Petitioner argued that the superior court's reliance on his mental health issues and treatment in refusing to re-probate him violated the Federal Americans with Disabilities Act. The single justice denied relief. The Supreme Judicial Court affirmed, holding that Petitioner's claims were appropriately raised in a direct appeal from the revocation of his probation. View "Burnham v. Commonwealth (No. 1)" on Justia Law

Posted in: Criminal Law
by
In this case regarding the mitigation of the spread of COVID-19 in the Commonwealth's prison decision the Supreme Judicial Court affirmed its prior decision, issued on April 3, 2020, as to the extent of the Court's constitutional authority to stay final sentences absent an ongoing challenge to the underlying conviction or a violation of constitutional rights, holding that the global stays of sentences sought by Petitioners would co-opt executive functions in ways that are not permitted by article 30 of the Massachusetts Declaration of Rights.Petitioners asked the Supreme Judicial Court to reconsider its determination that neither the Court's inherent judicial authority nor its superintendence authority permitted a judge to stay a final sentence that is being served, absent a pending appeal or a motion for a new trial, without violating separation of powers principles under article 30. Petitioners further challenged the court's order with respect to reporting requirements. The Supreme Judicial Court affirmed its prior decision but concluded that some of the requested relief as to additional reporting requirements should be allowed, and accordingly issued a revised Appendix B. View "Committee for Public Counsel Services v. Chief Justice of the Trial Court (No. 2)" on Justia Law

by
The Supreme Judicial Court affirmed the order of the superior court granting Plaintiff's motion for a preliminary injunction seeking immediate reinstatement to school after she was suspended for 152 school days for possessing a small amount of marijuana and two makeshift pipes in her locker at a public high school, holding that the motion judge did not err in concluding that Plaintiff was likely to succeed on the merits of her claim.When Plaintiff appealed from her suspension to the superintendent, the district's school safety director acting as the superintendent's designee shorted the suspension to 112 school days. Plaintiff filed a complaint alleging that, by delegating the appeal to the school safety director, Defendants failed to comply with the procedure for appealing from the expulsion set forth in Mass. Gen. Laws ch. 71, 37H(d). Plaintiff also filed an emergency motion for a preliminary injunction. The motion judge granted the preliminary injunction and reinstated Plaintiff to her high school. The Supreme Judicial Court affirmed, holding that because the principal initially imposed a suspension of 152 school days, Plaintiff was entitled under section 37H to appeal from her exclusion directly to the superintendent, not a designee of the superintendent. View "Doe v. Worcester Public Schools" on Justia Law

Posted in: Education Law
by
The Supreme Judicial Court affirmed the order of the superior court finding that Defendant committed a breach of contract and the implied covenant of good faith and fair dealing and awarding $10.2 million in damages, holding that the superior court did not abuse its discretion.The jury awarded Plaintiff in excess of $22 million in damages after Defendant withdrew its support for Plaintiff's research laboratory. The judge conditionally ordered a new trial unless Plaintiff agreed to remit all but $10.2 million of the awarded damages, which represented in part $10 million that Plaintiff testified was necessary to reestablish her laboratory. The Supreme Judicial Court affirmed, holding (1) the trial evidence supported the finding that Defendant committed a breach of both the express terms of the contract and the implied covenant of good faith and fair dealing; (2) the cost of reestablishing the laboratory was a permissible element of the damages; and (3) the judge did not abuse her discretion in adding a remittitur of all but $10.2 million of the award of damages. The judges were equally divided as to whether the $10 million should go to Plaintiff outright or subject to a restriction, and therefore, the award of damages stood without any restriction. View "Hlatky v. Steward Health Care System, LLC" on Justia Law

Posted in: Contracts
by
The Supreme Judicial Court affirmed the decision of the superior court granting summary judgment in favor of Susan Boss on her complaint seeking a declaration that the Town of Leveret was obligated to pay fifty percent of the full premium cost for health insurance for retired town employees and their dependent spouses, holding that by adopting Mass. Gen. Laws ch. 32B, 9A, the Town was required to cover fifty percent of the premiums for both retirees and the retirees' dependents.Boss was a retired Town employee. Since her retirement, the Town had paid fifty percent of her premium contribution based only on the premium cost for individual coverage. Consequently, Boss had been responsible for covering the balance of the plan premium in order to continue coverage for her spouse. Since become Medicare eligible, Boss continued to pay the full premium for her husband's individual plan. After Boss brought this action the superior court granted summary judgment in her favor. The Supreme Judicial Court affirmed, holding (1) the Town's adoption of section 9A obligated it to contribute toward the premiums associated with retirees' dependents; and (2) section 9A was successfully adopted at the Town meeting on April 24, 2004. View "Boss v. Town of Leverett" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition for extraordinary relief under Mass. Gen. Laws ch. 211, 3 seeking an order vacating Petitioner's plea to aggravated rape and dismissing the underlying indictment, holding that the single justice did not err or abuse his discretion in denying relief.The issues raised by Petitioner had all been raised and adjudicated through the normal appellate process. Petitioner then filed a motion to withdraw his guilty plea. The motion was denied, and the Appeals Court affirmed. In this petition for extraordinary relief, Petitioner sought an order vacating his plea to aggravated rape and dismissing the underlying indictment. The single justice denied relief. The Supreme Judicial Court affirmed, holding that the superintendence power was not available as an additional layer of appellate review once all other avenues had been exhausted. View "Garden v. Commonwealth" on Justia Law

Posted in: Criminal Law
by
The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Defendant was convicted of several offenses. The Appeals Court reversed the convictions and remanded the matter for a new trial. Thereafter, the Commonwealth filed a nolle prosequi as to all the charges. In his Mass. Gen. Laws ch. 211, 3 petition, Defendant alleged that no crime had been committed and that he was wrongfully prosecuted. The single justice denied relief. The Supreme Judicial Court affirmed, holding that Defendant did not demonstrate entitlement to the exercise of this Court's superintendence powers. View "In re Mitchell" on Justia Law

Posted in: Criminal Law
by
The Supreme Judicial Court reversed the order of the superior court denying Defendant's motion for a new trial and set aside the jury's verdicts of first degree murder and robbery, holding that a recently discovered witness statement made to the police ago constituted newly discovered evidence that "would probably have been a real factor in the jury's deliberations."At issue was Defendant's sixth motion for a new trial, which was predicated on newly discovered evidence consisting of, among other things, a recently discovered statement made to the police in 1972. The superior court denied the motion. As to the police statement, the judge found that it did not constitute newly discovered evidence because Defendant failed to establish that defense counsel did not have possession of it at the time of trial. The Supreme Judicial Court reversed and remanded the case for a new trial, holding (1) Defendant sustained his burden of establishing that defense counsel did not have the 1972 police statement prior to or at trial, and therefore, the statement constituted newly discovered evidence; and (2) there was a substantial risk that the jury would have reached a different conclusion had the evidence been admitted at trial. View "Commonwealth v. Mazza" on Justia Law

Posted in: Criminal Law
by
The Supreme Judicial Court granted Plaintiffs' emergency petition and allowed Plaintiff's application for declaratory relief to the extent that this Court declares, in light of emergency circumstances arising from the COVID-19 pandemic, that the minimum signature requirements in Mass. Gen. Laws ch. 53, 7 and 44 for candidates in the September 1, 2020 primary election are unconstitutional.Plaintiffs argued that, in the context of the current pandemic, the minimum signature requirements to be listed on the ballot for a party's nomination posed an unconstitutionally undue burden on Massachusetts would-be candidates' constitutional right to seek elective office. The Supreme Judicial Court agreed, holding (1) application of the signature requirements in the context of the current public health crisis imposes a severe burden a candidate's right to gain access to the September 1 primary ballot, triggering heightened scrutiny; and (2) in this time of pandemic, the justification for the current signature requirements cannot survive this scrutiny and are unconstitutional as applied to Plaintiffs. The Court fashioned equitable relief intended to substantially diminish that burden while respecting the legislative purpose for imposing minimum signature requirements. View "Goldstein v. Secretary of the Commonwealth" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the district court denying Defendant's motions to suppress, holding that the limited use of automatic license plate readers (ALPRs) in this case did not implicate constitutional protections against unreasonable searches.While police were investigating Defendant on suspicion of drug distribution they used ALPRs on two bridges to track Defendant's movements. The police accessed historical data via ALPR technology and received real-time alerts, the last of which led to Defendant's arrest. Defendant filed motions to suppress the ALPR data and the fruits of the arrest. The superior court denied the motions. The Supreme Judicial Court affirmed, holding that while the widespread use of ALPRs in the Commonwealth could implicate a defendant's constitutional protected expectation of privacy in the whole of his public movements, that interest was not invaded by the limited extent and use of the ALPR data in the instant case. View "Commonwealth v. McCarthy" on Justia Law