Justia Massachusetts Supreme Court Opinion Summaries

The case pertains to an appeal by plaintiff William J. Papp, III, against the decision of a single justice of the Supreme Judicial Court denying his request for declaratory relief, a stay of eviction, and relief in the nature of certiorari in relation to a housing dispute. The dispute centered around Papp's objection to the transfer of his case against the defendant landlord from the Superior Court to the Central Division of the Housing Court Department, which he alleged was in violation of G. L. c. 185C, § 20 and deprived him of due process.The Supreme Judicial Court upheld the single justice's decision, affirming that Papp had failed to adequately demonstrate that other remedies were not available to him. The court noted that Papp could have sought interlocutory review of the transfer order from a single justice of the Appeals Court, as per G. L. c. 231, § 118, first par. Additionally, he could have appealed the transfer order as part of an appeal from the final judgment of the Housing Court. Therefore, since Papp could not establish the absence or inadequacy of other remedies, the single justice had not erred or abused her discretion in denying Papp's claims for relief. View "Papp v. Westborough Gardens LLC" on Justia Law

In a case before the Supreme Judicial Court, the Attorney General of Massachusetts initiated a civil action in the Superior Court alleging housing discrimination by the defendant, Mark Davidson, on behalf of two complainants. The defendant transferred the case to the Housing Court, after which the Attorney General unsuccessfully sought to have the matter transferred back to the Superior Court, arguing that the Housing Court lacked jurisdiction over a discrimination claim in this procedural posture. The complainants had initially filed an administrative complaint with the Massachusetts Commission Against Discrimination, alleging that the defendant had terminated their lease upon learning that one of the complainants was pregnant, allegedly to avoid having to comply with the lead containment or abatement statute. The defendant chose to have the matter heard in court rather than by the commission.The Supreme Judicial Court held that, based on the language of G. L. c. 151B, § 5, the Superior Court is the proper court for actions such as this one, and that the Housing Court lacks jurisdiction. The court reasoned that the language of § 5 unambiguously indicates that the Superior Court is the proper court for such actions. The court also noted that the Legislature's use of the word "shall" suggests a command to commence the action in the Superior Court, and not elsewhere, and the phrase "commence and maintain" is a clear directive that such actions brought by the Attorney General, once initiated, are to remain in the Superior Court. Therefore, the order of the single justice of the Appeals Court was affirmed, and the stay of any proceedings in the Superior Court was vacated. The case must be returned to the Superior Court. View "Commonwealth v. Davidson" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court dismissing FCA US LLC from the underlying tort lawsuit, holding that Massachusetts had personal jurisdiction over FCA US under the Commonwealth's long-arm statute, Mass. Gen. Laws ch. 223A, 3, and the due process clause of the Fourteenth Amendment.Paul Doucet was the passenger in a car that was involved in an accident in New Hampshire, rendering him incapacitated. Doucet's guardians filed suit against FCA US, the vehicle's manufacturer, and the Massachusetts distributor-dealership Sudbay Chrysler Dodge, Inc. FCA US, a Delaware limited liability company with its principal place of business in Michigan, filed a motion to dismiss for want of personal jurisdiction. The trial judge granted the motion and dismissed FCA US as a party to the case, concluding that Massachusetts lacked personal jurisdiction under both the long-arm statute and the due process clause of the United States Constitution. The Supreme Judicial Court vacated the judgment below, holding that personal jurisdiction existed in Massachusetts over FCA US for the underlying claims pursuant to both the Commonwealth's long-arm statute and the Fourteenth Amendment's due process clause. View "Doucet v. FCA US LLC" on Justia Law

The Supreme Judicial Court held that the comprehensive remedial scheme provided by the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., for recovery of damages when an employer violates the federal overtime law, 29 U.S.C. 207, precludes an employee from alternatively pursuing remedies under the wage act, Mass. Gen. Laws ch. 149, 148, for the untimely payment of overtime wages due solely pursuant to the FLSA.Plaintiffs, employees of Defendant, brought this action alleging violations of the FLSA for failure to pay overtime wages, violations of the wage act for failure to pay the FLSA overtime wages in a timely manner, and violations of federal and state minimum wage laws. The motion judge allowed summary judgment as to Defendant's liability under the federal overtime law and wage act. After a trial, the trial judge awarded damages. The Supreme Court remanded the case, holding (1) the trial judge's trebling of damages pursuant to the wage act was error; (2) the jury instructions for the calculation of overtime wages under the FLSA contained a methodological error; and (3) Defendant's remaining claims lacked merit. View "Devaney v. Zucchini Gold, LLC" on Justia Law

The Supreme Judicial Court held that the doctrine of present execution does not permit an interlocutory appeal from a superior court judge's order denying a motion to enforce an alleged settlement agreement.Plaintiff filed this action asserting claims for summary process eviction and breach of contract regarding Defendant's lease of office space. The parties' counsel engaged in settlement negotiations via e-mail. Thereafter, Defendant moved to enforce what it asserted was a binding settlement agreement. After the motion judge denied the motion Defendant filed a petition for interlocutory review asserting that its interlocutory appeal was proper under the doctrine of present execution. A single justice presented questions for appellate review. The Supreme Judicial Court dismissed the appeal, holding that Defendant was not entitled to an interlocutory appeal under the doctrine of present execution. View "CP 200 State, LLC v. CIEE, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the court denying Petitioner's petition for relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse the justice's discretion in denying relief.In his petition, Petitioner sought interlocutory relief from "undue delays" and "unreasonable decision[s]" by superior court judges in two civil cases in which he was a plaintiff and then requested that action on his petition be postponed due to circumstances related to the COVID-19 pandemic. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that Petitioner failed to establish why the trial court's decision could not adequately be obtained on appeal or by other available means. View "Negron v. Turco" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court recognizing an Israeli judgment under the Massachusetts Uniform Foreign Money-Judgments Recognition Act, Mass. Gen. Laws ch. 235, 23A, thus allowing the foreign money judgment to be enforced, holding that the superior court did not err.Defendant failed to pay Plaintiff, an Israeli law firm, its agreed-upon fees, and an Israeli court held Defendant liable for the debt. Thereafter, Plaintiff brought this action seeking to recognize the Israeli judgment under the recognition act. The judge recognized the judgment, allowing it to be enforced. The Supreme Judicial Court affirmed, holding (1) the recognition act does not require compliance with Mass. R. Civ. P. 4(d), as amended, but is best understood as requiring the same level of notice as required by due process; and (2) the Israeli judgment was not repugnant and did not offend public policy. View "Cassouto-Noff & Co. v. Diamond" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition filed under Mass. Gen. Laws ch. 211, 3, holding that Petitioner's petition failed because of adequate alternative remedies.Petitioner asked the county court to order the clerk of the superior court to enter a final judgment in certain proceedings in that court. The judge denied the motion, concluding that the petition failed because there existed an adequate alternative remedy. Petitioner then filed his current petition asking the court to direct the trial court to either enter judgment or schedule a trial. A single justice denied relief. The Supreme Judicial Court affirmed, holding that Petitioner's petition failed because of an adequate alternative remedy. View "Bishay v. Superior Court Department of the Trial Court" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's complaint for relief in the nature of mandamus and for extraordinary relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief.On March 31, 2017, judgment entered against Petitioner in the underlying superior court case. Petitioner filed a motion to vacate the judgment. After the motion to vacate was denied Petitioner filed a motion for reconsideration and a motion to recuse. Both motions were denied. Petitioner then filed her complaint for relief in the nature of mandamus and for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3. The single justice denied relief. The Supreme Judicial Court affirmed, holding that where Petitioner had an adequate alternative avenue to obtain the relief sought - an appeal to the Appeals Court - and chose not to pursue that avenue, Petitioner was not entitled to invoke the extraordinary relief set forth in Mass. Gen. Laws ch. 211, 3. View "Harrington v. Deutsche Bank National Trust Co." on Justia Law

The Supreme Judicial Court vacated the decision of the probate and family court judge's dismissal of Petitioner's third petition for adoption due to lack of jurisdiction, holding that the probate and family court had both subject matter jurisdiction and personal jurisdiction.Petitioner was the biological father of the child at issue and was named as the child's parent on her birth certificate. Petitioner lived outside of the United States with his same-sex partner and the child, where the child was born outside of marriage to a gestational carrier, the child's birth mother, who lived in Massachusetts. Mother signed a surrender form indicating her desire to surrender the child to the care and custody of Father. Thereafter, Father filed three petitions in the probate and family court seeking to establish his status as the child's sole legal parent. Each petition was rejected. Father appealed the denial of his third petition, which was rejected on the basis that the court lacked jurisdiction. The Supreme Judicial Court vacated the judgment, holding that the probate and family court had subject matter jurisdiction under Mass. Gen. Laws ch. 210, 1 and personal jurisdiction over the parties in this case. View "In re Adoption of Daphne" on Justia Law