Justia Massachusetts Supreme Court Opinion Summaries

Defendant was charged with violating Mass. Gen. Laws ch. 56, 42, which criminalizes certain false statements about political candidates or questions submitted to voters, after her political action committee published brochures criticizing a candidate for public office. Defendant filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 seeking relief from the criminal complaint on the ground that section 42 is unconstitutional. The Supreme Judicial Court granted the requested relief, holding (1) section 42 is inconsistent with the fundamental right of free speech enshrined in article 16 of the Massachusetts Declaration of Rights and is, therefore, invalid; and (2) accordingly, the criminal complaint charging Defendant with violating section 42 must be dismissed. View "Commonwealth v. Lucas" on Justia Law

A franchisee janitorial worker, on behalf of himself and other similarly situated individuals, filed a complaint against System4 LLC, a master franchisor, and NECCS, Inc., a regional subfranchisor, alleging, among other claims, breach of contract, misclassification as independent contractors in their franchise agreements, and rescission of the franchise agreements. The franchise agreements, signed only by Plaintiffs and NEECS, required the franchisees to arbitrate virtually all disputes. Defendants, citing the arbitration clause in the franchise agreement, moved to stay the court proceedings pending arbitration. The judge concluded that because System4 was not a nonsignatory to the agreements, Plaintiffs could proceed to litigate their claims against System4 in court. The Supreme Judicial Court reversed, holding that, by reason of equitable estoppel, System4 could compel Plaintiffs to arbitrate their substantive claims in accordance with the arbitration provision in Plaintiffs’ franchise agreements. Remanded. View "Machado v. System4 LLC" on Justia Law

At issue in this case were amendments to the Sex Offender Registry Law that the Governor signed into law on July 12, 2013, including amendments that would require the Sex Offender Registry Board (SORB) to publish on the Internet information contained in the sex offender registry regarding individuals given a level two or three classification. On July 5, 2013, Plaintiffs, as putative representatives of a class of persons presently and prospectively classified as level two sex offenders, filed a complaint for declaratory and injunctive relief seeking an injunction barring SORB from publishing registry information on the Internet of the class of level two offenders. The Supreme Judicial Court declared unconstitutional the retroactive application of the amendments to the extent they would require the Internet publication of the registry information of individuals who were finally classified as level two sex offenders on or before July 12, 2013 but noted that SORB was allowed to publish on the Internet the registry information of any individual who was given a final classification as a level two sex offender after July 12, 2013. View "Moe v. Sex Offender Registry Bd." on Justia Law

In Feeney II, the Massachusetts Supreme Court affirmed the ruling of the superior court invalidating a class action waiver in the parties' arbitration agreement, holding that the Federal Arbitration Act (FAA) does not foreclose a court from invalidating an arbitration agreement that includes a class action waiver if it effectively denies the plaintiffs a remedy. The U.S. Supreme Court subsequently issued an opinion in American Express Co. v. Italian Colors Restaurant (Amex) holding that a class action waiver in an arbitration agreement is enforceable under the FAA even if a plaintiff proves that the class waiver effectively precludes the plaintiff from vindicating his federal statutory rights. The Massachusetts Supreme Court subsequently concluded that following Amex, the Court's analysis in Feeney II no longer comported with the U.S. Supreme Court's interpretation of the FAA, holding instead that a class waiver may not be invalidated on the grounds that it effectively denies the plaintiffs a remedy. Remanded. View "Feeney v. Dell Inc. " on Justia Law

Plaintiffs were individuals who entered into contracts with Defendants for the provision of janitorial services to third-party customers. Plaintiffs filed this putative class action, alleging that Defendants violated the Massachusetts Wage Act. Defendants moved to stay the court proceedings pending arbitration according to the terms of the arbitration clause contained in the parties' franchise agreements. The superior court denied the motion, concluding that the arbitration clause was unenforceable as set forth in Feeny v. Dell Inc. (Feeney I). After the United States Supreme Court decided AT&T Mobility LLC v. Concepcion, Defendants sought appellate review, which the Supreme Court granted. The Supreme Court reversed the order invalidating the arbitration in light of its interpretation of Conception and its impact on Feeney I, as set forth in Feeney II, holding (1) Massachusetts public policy in favor of class proceedings in certain contexts may no longer serve, in and of itself, as grounds to invalidate a class waiver in an arbitration agreement; and (2) in this case, Plaintiffs failed to demonstrate they lacked a practical means to pursue their claims on an individual basis. View "Machado v. System4 LLC" on Justia Law

Plaintiffs commenced a putative class action against Defendant, alleging violations of Mass. Gen. Laws ch. 93A. Dell successfully moved to compel arbitration according to an arbitration agreement signed by the parties. An arbitrator concluded that the parties waived class action relief by signing the agreement. In Feeney I, the Supreme Court invalidated the class waiver provision in the arbitration agreement. In this subsequent appeal, the Supreme Court held that the arbitration agreement was properly invalidated where (1) Mobility LLC v. Concepcion, decided by the U.S. Supreme Court after Feeney I, precluded the invalidation of class waiver provisions in arbitration clauses in consumer contracts, such as the one at issue here, and therefore, Concepcion undid the principal rationale for the Court's decision in Feeney I; (2) a court is not foreclosed from invalidating an arbitration agreement that includes a class action waiver where a plaintiff can demonstrate he effectively cannot pursue a claim against the defendant in individual arbitration according to the terms of his agreement, thus rendering his or her claim nonremediable; and (3) Plaintiffs demonstrated that they could not pursue their statutory claim under the individual claim arbitration process required by the arbitration agreement. View "Feeney v. Dell Inc." on Justia Law

Plaintiff filed suit against Liberty Mutual, both personally and on behalf of a putative class of similarly situated individuals, alleging that the company's failure to disburse "medical payments" coverage (MedPay) benefits to her constituted a breach of contract, a breach of implied covenant of good faith and fair dealing, and a violation of G.L.c. 93A, 2. At issue was whether a claimant could seek medical expense benefits under the MedPay of a standard Massachusetts automobile insurance policy where she had already recovered for those expenses under a separate policy of health insurance. The court held that plaintiff's complaint and the extrinsic materials submitted by Liberty Mutual contained alleged facts sufficient to "raise a right to relief above the speculative level." The court also held that Liberty Mutual had not demonstrated as a matter of law that plaintiff could not receive MedPay benefits when she already had received medical expense benefits under her policy of health insurance. Accordingly, the order allowing Liberty Mutual's motion to dismiss was reversed and the matter remanded. View "Golchin v. Liberty Mutual Ins. Co." on Justia Law