Justia Massachusetts Supreme Court Opinion Summaries

The plaintiff filed a complaint in the Land Court regarding a property in Duxbury, claiming ownership following a foreclosure sale. The defendants, who had executed a mortgage in favor of the plaintiff's predecessor, refused to vacate the property. The Land Court judge ruled in favor of the plaintiff, declaring them the lawful owner. The defendants appealed this decision.Subsequently, the plaintiff filed a summary process complaint in the Housing Court to gain possession of the property and requested use and occupancy payments from the defendants during the litigation. The Housing Court judge granted this request but stayed the proceedings pending the appeal of the Land Court judgment. The defendants sought interlocutory relief from a single justice of the Appeals Court, who vacated the Housing Court's order, stating that the Housing Court judge had not determined ownership.The plaintiff renewed their motion in the Housing Court, which was again granted, with the judge explicitly relying on the Land Court's judgment under the doctrine of res judicata. The defendants again sought relief from the single justice, who vacated the order, arguing that the Housing Court judge's reliance on the appealed Land Court judgment was improper. The plaintiff was granted leave to appeal to a full panel of the Appeals Court, and the Supreme Judicial Court transferred the case on its own motion.The Supreme Judicial Court held that a judge hearing a summary process action for possession may rely on a final judgment of the Land Court regarding ownership, even if an appeal is pending. The court confirmed that the Land Court's judgment had preclusive effect, allowing the Housing Court judge to order interim use and occupancy payments. The order of the single justice was reversed, and the defendants' petition for relief was denied. View "TJR Services LLC v. Hutchinson" on Justia Law

A clerk-magistrate decided to allow public access to show cause hearings for individuals accused of being clients of a prostitution ring but denied media requests for the underlying complaint applications before the hearings. The accused individuals, referred to as John Does, intervened to oppose the public access decision and sought to keep the hearings private. The media outlets filed a petition in the Supreme Judicial Court for Suffolk County to challenge the clerk-magistrate's decision to withhold the complaint applications.The single justice of the Supreme Judicial Court remanded the matter to the clerk-magistrate for written findings on specific questions related to the public interest and privacy concerns. After reviewing the clerk-magistrate's responses, the single justice denied the petition, concluding that the clerk-magistrate did not commit an error of law or abuse her discretion in allowing public access to the hearings and denying access to the complaint applications.The Supreme Judicial Court affirmed the single justice's decision, holding that the clerk-magistrate acted within her discretion. The court found that the public interest in transparency and accountability outweighed the privacy interests of the accused, especially given the significant public attention and the potential for favoritism if the hearings were held privately. The court also agreed that denying access to the complaint applications was appropriate to prevent the dissemination of potentially erroneous or extraneous information before the accused had an opportunity to respond at the hearings.The court further directed the Trial Court to provide notice to the accused when a request for public access to a show cause hearing is made and to offer the accused an opportunity to respond before deciding on the request. View "Trustees of Boston University v. Clerk-Magistrate of the Cambridge Division of the District Court Department" on Justia Law

Bruce Johnson and Caroline Settino were engaged to be married, with Johnson giving Settino a $70,000 diamond engagement ring and two wedding bands. Johnson also paid for various expenses, including part of Settino's dental implant surgery. However, Johnson ended the engagement after discovering messages on Settino's phone that led him to believe she was unfaithful, although the trial judge found no evidence of an affair. Settino kept the engagement ring and wedding bands, and Johnson did not pay for the second part of Settino's dental procedure.Johnson sued to recover the engagement ring and wedding bands, and Settino counterclaimed for the cost of the dental procedure. The Superior Court judge ruled in favor of Settino, allowing her to keep the engagement ring and one wedding band, and awarded her damages for the dental procedure, including prejudgment interest from the date of Johnson's complaint. The judge found Johnson at fault for ending the engagement based on his mistaken belief of infidelity.The Appeals Court reversed the decision, ruling that Johnson was not at fault and should recover the engagement ring and wedding band. The court also found that prejudgment interest should be calculated from the date of Settino's counterclaim, not Johnson's complaint. The Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court of Massachusetts held that the concept of fault should not determine the return of engagement rings. The court adopted a no-fault approach, requiring the return of the engagement ring and wedding bands to the donor if the marriage does not occur, regardless of fault. The court also affirmed the need to recalculate prejudgment interest from the date of Settino's counterclaim. The judgment was reversed in part and remanded for recalculation of prejudgment interest. View "Johnson v. Settino" on Justia Law

The plaintiff, Kathleen Vita, alleged that New England Baptist Hospital (NEBH) and Beth Israel Deaconess Medical Center, Inc. (BIDMC) violated the Massachusetts wiretap act by collecting and transmitting her browsing activities on their websites to third parties for advertising purposes without her consent. Vita accessed information about doctors and medical conditions on the hospitals' websites and claimed these interactions were "wire communications" protected by the wiretap act. She did not allege that private patient records or messages to healthcare providers were intercepted.The Superior Court denied the hospitals' motions to dismiss Vita's complaints, leading to the hospitals' appeal. The Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the term "communication" in the wiretap act is ambiguous as applied to web browsing activities. The court found that the legislative history of the wiretap act focused on the secret interception of person-to-person conversations and messaging, particularly private ones, and did not clearly extend to interactions with websites. Given this ambiguity, the court applied the rule of lenity, which requires that any ambiguity in a criminal statute be resolved in favor of the defendant. Consequently, the court concluded that the wiretap act does not unambiguously prohibit the interception of web browsing activities and reversed the Superior Court's denial of the hospitals' motions to dismiss. View "Vita v. New England Baptist Hospital" on Justia Law

The case involves Susan Hartnett, a public employee who worked for the Commonwealth from 1978 to 1990 and then rejoined public service in 2002, working for the city of Boston. Upon her return, her salary more than doubled compared to her 1990 salary. Hartnett continued working until 2006 and deferred her retirement until 2016. Initially, her pension was calculated without applying the anti-spiking provision of the public employee pension statute, but after an audit, the Boston Retirement System (BRS) applied the provision, reducing her pension.Hartnett challenged the application of the anti-spiking provision. The Division of Administrative Law Appeals (DALA) and the Contributory Retirement Appeal Board (CRAB) affirmed BRS's decision. Hartnett then sought judicial review in the Superior Court, which ruled in her favor, concluding that the anti-spiking provision did not apply because the years 1990 and 2002 were not "two consecutive years" under the statute. The agencies appealed, and the case was transferred to the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court of Massachusetts held that the phrase "two consecutive years" in the anti-spiking provision refers to two back-to-back years without interruption. The court found that the plain meaning of "consecutive" means following one after another without interruption, and this interpretation is consistent with the statutory scheme. The court rejected the agencies' argument that "two consecutive years" should mean two creditable years of service without another intervening year of service. Consequently, the court affirmed the Superior Court's judgment in favor of Hartnett, ruling that the years 1990 and 2002 are not "two consecutive years" under the anti-spiking provision. View "Hartnett v. Contributory Retirement Appeal Board" on Justia Law

The plaintiffs, a group of professional models, alleged that the defendant, an adult entertainment nightclub, used their images in social media posts without consent to promote the club between August 2013 and November 2015. The plaintiffs filed a lawsuit in 2021 in the United States District Court for the District of Massachusetts, claiming defamation and related torts. This filing was outside the three-year statute of limitations specified by Massachusetts law. To avoid dismissal, the plaintiffs argued for the application of the "discovery rule," which would delay the start of the limitations period until they knew or reasonably should have known about the harm.The United States District Court for the District of Massachusetts noted that the application of the discovery rule to social media posts was a novel issue in Massachusetts law. The court certified a question to the Supreme Judicial Court of Massachusetts, asking under what circumstances material posted on social media platforms could be considered "inherently unknowable" for the purposes of applying the discovery rule in defamation and related tort claims.The Supreme Judicial Court of Massachusetts held that claims arising from social media posts accrue when a plaintiff knows or reasonably should know they have been harmed by the publication. The court emphasized that the vastness of social media and the variability in access and searchability require a fact-specific inquiry. The court concluded that whether the plaintiffs knew or should have known about the harm must often be determined by the finder of fact. However, if the social media material is widely distributed and readily accessible and searchable, a judge may determine as a matter of law that the discovery rule does not apply. View "Davalos v. Bay Watch, Inc." on Justia Law

In 2016, the Federal National Mortgage Association (Fannie Mae) acquired the high bid at a foreclosure sale of Anthony Michael Branch's property. Fannie Mae then initiated a summary process action in the Housing Court to gain possession. The court ruled in favor of Fannie Mae, and Branch appealed. During the appeal, Fannie Mae sold the property to Roberto Pina Cardoso. Cardoso intervened in the case and was awarded use and occupancy payments from Branch. The Appeals Court later vacated the Housing Court's judgment for possession, declaring it moot since Fannie Mae no longer had a possessory interest, and required Cardoso to establish his right to possession in a new case.The Housing Court initially granted summary judgment in favor of Fannie Mae for possession and dismissed Branch's counterclaims. Branch appealed, and during the appeal, Cardoso was allowed to intervene and was joined as a party with Fannie Mae. The Appeals Court vacated the judgment for possession as moot but affirmed the dismissal of Branch's counterclaims.The Supreme Judicial Court of Massachusetts reviewed the case and disagreed with the Appeals Court's mootness determination. The court held that Cardoso, having acquired Fannie Mae's interest, maintained a live stake in the adjudication of the judgment for possession. The court affirmed the Housing Court's order allowing Cardoso to intervene and be joined as a party. It also affirmed the summary judgment in favor of Fannie Mae for possession and the dismissal of Branch's counterclaims. The court concluded that the foreclosure was valid and that Pentagon Federal Credit Union, as the authorized agent of the note holder, had the authority to foreclose. View "Fannie Mae v. Branch" on Justia Law

The case involves Pure Oasis LLC, which applied for a conditional use permit to operate a recreational cannabis dispensary in Boston. The building commissioner denied the permit, and Pure Oasis appealed to the Board of Appeal of Boston. After multiple hearings, the board approved the permit. William Shoucair, an abutter to the property, opposed the permit, arguing it would negatively impact the neighborhood and filed a complaint in the Superior Court in Suffolk County, appealing the board's decision.The Superior Court judge ordered each plaintiff to post a $3,500 bond, despite not finding the appeal to be in bad faith. The judge applied the standard from Damaskos v. Board of Appeal of Boston, which allows for a bond to discourage frivolous appeals while not obstructing meritorious ones. The plaintiffs sought interlocutory review, and a single justice of the Appeals Court stayed the bond order and allowed an interlocutory appeal. The Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that under Section 11 of the Boston zoning enabling act, a preliminary finding of bad faith or malice is not required before imposing a bond for damages. The court reaffirmed the standard from Damaskos, which balances discouraging frivolous appeals with not obstructing meritorious ones. The court found no abuse of discretion by the lower court judge in setting the bond amount and affirmed the order. View "Shoucair v. Board of Appeal of Boston" on Justia Law

A general contractor, Graycor Construction Company Inc., was involved in a dispute with a subcontractor, Business Interiors Floor Covering Business Trust, over unpaid invoices for flooring work performed on a movie theater project. Business Interiors submitted three separate applications for periodic payments, which Graycor neither approved nor rejected within the time limit set by the Prompt Pay Act. As a result, the applications were deemed approved under the Act. Business Interiors sued Graycor for breach of contract and other claims in the Superior Court. The Superior Court granted Business Interiors's motion for summary judgment on its breach of contract claim and entered separate and final judgment. Graycor appealed.Graycor argued that the original contract was not a "contract for construction" within the meaning of the Act, and that it had a valid impossibility defense due to its failure to pay. The Supreme Judicial Court held that the Act defines its scope broadly, and the subcontract at issue was a "contract for construction" under the Act. The Court also held that common-law defenses are not precluded by the Act, but a contractor that does not approve or reject an application for payment in compliance with the Act must pay the amount due prior to, or contemporaneous with, the invocation of any common-law defenses in any subsequent proceeding regarding enforcement of the invoices. As Graycor sought to exercise its defenses without ever paying the invoices, it could not pursue the defenses. The Court also vacated and remanded the rule 54 (b) certification to the motion judge for reconsideration. View "Business Interiors Floor Covering Business Trust v. Graycor Construction Company Inc." on Justia Law

The case involves a dispute over the eligibility of a married individual, Costa Tingos, for Medicaid long-term care benefits. Costa and his wife, Mary, had been married for over 50 years, but had kept their finances largely separate due to Costa's history of gambling and financial mismanagement. When Costa moved into a nursing home, he applied for Medicaid benefits. However, Mary refused to provide information about her income and assets, which was necessary to determine Costa's eligibility. Costa argued that Mary's refusal to cooperate should not affect his eligibility.The case was initially heard by the Massachusetts Medicaid program, MassHealth, which denied Costa's application. Costa appealed to the MassHealth board of hearings, which also denied his appeal. Costa then sought judicial review in the Superior Court, which vacated the board's decision and remanded the case back to the board. After two more rounds of hearings and appeals, the Superior Court affirmed the board's decision to deny Costa's application.The Supreme Judicial Court of Massachusetts affirmed the decision of the Superior Court. The court held that the board's interpretation of the phrase "refuses to cooperate" in the relevant regulation was reasonable. The court found that Mary's refusal to disclose her financial information did not constitute a refusal to cooperate within the meaning of the regulation, given the couple's long history of cooperation in other aspects of their marriage. The court also rejected Costa's argument that the board's decision was arbitrary and capricious. View "Freiner v. Secretary of the Executive Office of Health and Human Services" on Justia Law