Justia Massachusetts Supreme Court Opinion Summaries

An individual pleaded guilty to multiple sexual offenses committed against two girls, aged thirteen and fourteen, when he was eighteen years old. The offenses included several instances of rape and indecent assault. The individual had a history of psychological diagnoses, including autism spectrum disorder. After his conviction, the Sex Offender Registry Board (SORB) initially classified him as a level three sex offender, which would require the highest level of public notification. The individual challenged this classification, leading to a de novo hearing before a SORB hearing examiner.At the hearing, the examiner found by clear and convincing evidence that the individual posed a moderate risk of reoffense and a moderate degree of danger, resulting in a reclassification to level two. The examiner considered several statutory and regulatory factors, including the number of victims, the nature and location of the offenses, and the individual’s psychological profile. The examiner also considered the fact that the individual committed multiple offenses, including repeated offenses against one victim, as relevant to the degree of dangerousness. The examiner determined that Internet publication of the individual’s registration information would serve a public safety interest. The individual sought judicial review in the Massachusetts Superior Court, which affirmed the SORB’s decision.The Supreme Judicial Court of Massachusetts reviewed the case after transferring it from the Appeals Court. The court held that the SORB hearing examiner did not err in considering the individual’s multiple offenses as relevant to dangerousness under regulatory factor thirty-seven, even though such consideration is limited under factor two, which addresses risk of reoffense. The court also declined to find the application of factor thirty-seven unconstitutional due to a lack of empirical evidence, given the statutory mandate to consider the number of offenses. The court affirmed the classification as a level two offender and the requirement for Internet dissemination of registration information. View "Doe v. Sex Offender Registry Board" on Justia Law

The case concerns an individual who, after responding to an online advertisement posted by an undercover police officer posing as two twenty-year-old women, learned that the supposed women were actually fifteen years old. Despite this, he continued to arrange a meeting for sexual services in exchange for money, drove from Massachusetts to Rhode Island, and was arrested upon arrival. He was found in possession of cocaine and ultimately pleaded nolo contendere in Rhode Island to indecent solicitation of a child, receiving a suspended sentence and probation. The individual also had a prior history of criminal justice involvement, including violations of abuse prevention orders and drug-related charges.Following his conviction, the Massachusetts Sex Offender Registry Board (SORB) issued a preliminary determination classifying him as a level two sex offender. After a de novo hearing, a SORB hearing examiner confirmed this classification, applying several risk-elevating factors, including targeting children, stranger victims, substance abuse, criminal justice contact, hostility towards women, and number of victims. The individual challenged the classification in the Massachusetts Superior Court, arguing that the decision was arbitrary, capricious, and unsupported by substantial evidence, particularly contesting the application of certain risk factors. The Superior Court denied his motion for judgment on the pleadings and affirmed the SORB decision.The Supreme Judicial Court of Massachusetts reviewed the case after transferring it from the Appeals Court. The court held that the hearing examiner did not abuse discretion in applying or weighing the challenged risk factors. However, the court found that the hearing examiner’s written decision was ambiguous regarding whether the individual’s information should be disseminated to the public, which is essential for determining the proper classification level. As a result, the Supreme Judicial Court vacated the Superior Court’s judgment and remanded the matter to SORB for a clear, written conclusion on both the need for dissemination and the classification level. View "Doe, Sex Offender Registry Board No. 528042 v. Sex Offender Registry Board" on Justia Law

A former Massachusetts State Police trooper retired in March 2018 after a 21-year career. While assigned to overtime patrol programs funded by federal grants, he falsely reported working over 700 overtime hours in 2015 and 2016, receiving more than $50,000 in unearned pay. He attempted to conceal his conduct by submitting falsified motor vehicle citations. In July 2018, he pleaded guilty in federal court to one count of embezzlement from an agency receiving federal funds, was sentenced to three months in prison, one year of supervised release, and ordered to pay restitution.Following his conviction, the State Board of Retirement suspended his pension and held a hearing. The hearing officer recommended, and the board adopted, a finding that under G. L. c. 32, § 15 (4), the plaintiff and his beneficiaries were not entitled to any retirement benefits due to his conviction for an offense involving violation of laws applicable to his office. The board ordered the return of his accumulated contributions, less certain deductions. The plaintiff sought judicial review in the Massachusetts District Court, raising constitutional challenges under Article 26 of the Massachusetts Declaration of Rights, arguing the forfeiture was an excessive fine and cruel or unusual punishment. The District Court judge entered judgment for the retirement board.The Supreme Judicial Court of Massachusetts reviewed the case on certiorari. It held that the pension forfeiture constituted a fine under Article 26 but was not excessive, adopting the United States Supreme Court’s multifactor analysis for excessive fines under the Eighth Amendment. The court also held that, even assuming Article 26’s cruel or unusual punishment provision applied to fines, the forfeiture was not cruel or unusual. The court affirmed the District Court’s judgment and the retirement board’s decision. View "Raftery v. State Board of Retirement" on Justia Law

The case involves the Massachusetts Insurers Insolvency Fund (MIIF) seeking cost-of-living adjustment (COLA) payment reimbursements from the Workers' Compensation Trust Fund (trust fund). MIIF, a nonprofit entity created by statute, administers and pays certain claims against insolvent insurers. Between 1989 and 2013, MIIF paid workers' compensation benefits, including COLA payments, on behalf of several insolvent insurers. MIIF filed claims with the trust fund for reimbursement of these payments, but the trust fund denied the claims, arguing that MIIF is not an "insurer" under the relevant statutes and does not participate in the trust fund.The Department of Industrial Accidents (DIA) administrative judge denied MIIF's claims, and the Industrial Accident Reviewing Board (board) affirmed the decision. The board relied on the Appeals Court's decision in Home Ins. Co. v. Workers' Compensation Trust Fund, concluding that MIIF, like the insolvent insurers, does not collect and transmit assessments to the trust fund and is therefore not entitled to reimbursement.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that MIIF is eligible for COLA-payment reimbursements. The court determined that MIIF, when taking on an insolvent insurer's covered claims, is "deemed the insurer" and has "all rights, duties, and obligations" of the insolvent insurer under G. L. c. 175D, § 5 (1) (b). The court also found that the plain language of the relevant statutes does not exclude MIIF from reimbursement eligibility and that the trust fund's funding mechanism, which is paid for by employers, supports MIIF's entitlement to reimbursement.The Supreme Judicial Court reversed the board's decision and remanded the case for further proceedings consistent with its opinion. View "Massachusetts Insurers Insolvency Fund v. Workers' Compensation Trust Fund" on Justia Law

Michael Cannata served as a firefighter for the town of Mashpee for over a decade before leaving in 2004 as a "deferred retiree." During his employment, he was enrolled in the town's group health insurance plan, but his enrollment ended upon his departure. In 2021, after turning fifty-five and beginning to collect retirement benefits, Cannata sought to re-enroll in the town's health insurance plan as a retiree. The town denied his request, citing various reasons, including his lack of "time in-service" and the town's practice of denying coverage to retirees not enrolled in the plan at the time of retirement.Cannata filed an action in the Superior Court, seeking a judgment declaring that the town's denial of benefits violated G. L. c. 32B, § 9. The Superior Court judge granted the town's motion to dismiss for failure to state a claim, concluding that Cannata was required to apply for continued coverage and pay the full premium cost during his deferral period in order to later enroll in the town's group health insurance plan upon retirement. Cannata appealed the decision.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that G. L. c. 32B, § 9, neither requires nor prohibits a municipality from enrolling individuals like Cannata in its group health insurance plan upon retirement. The court concluded that the third paragraph of the statute, which the lower court relied on, did not govern Cannata's case. The court determined that municipalities may, but are not obligated to, allow such individuals to enroll in group health insurance upon retirement. The court affirmed the judgment of dismissal on the alternative ground that Cannata's complaint failed to plausibly allege entitlement to relief beyond a speculative level. The case was remanded with instructions to dismiss the complaint without prejudice, allowing Cannata an opportunity to amend his request for declaratory relief. View "Cannata v. Town of Mashpee" on Justia Law

In 2023, Kenneth Bresler, a former Appeals Court staff attorney, filed a lawsuit in the Superior Court against three Appeals Court employees, Lynn Muster, Mary Bowe, and Gina DeRossi, alleging intentional interference with advantageous relations. Bresler claimed that the defendants engaged in a campaign that led to his termination. The defendants moved to dismiss the complaint, arguing that Bresler failed to establish the "actual malice" required for such a claim and that they were entitled to common-law immunity as public officials.The Superior Court judge granted the motion to dismiss for Bowe and DeRossi but denied it for Muster. Bresler appealed the dismissal of Bowe and DeRossi, while Muster cross-appealed the partial denial of her motion to dismiss. The Supreme Judicial Court granted Bresler's application for direct appellate review.The Supreme Judicial Court reviewed the case and concluded that the allegations in the complaint, when taken as true, plausibly suggested that Muster and Bowe acted with "actual malice," which is necessary to state an intentional interference claim. The court found that Muster's actions, motivated by jealousy and hostility, and Bowe's subsequent negative evaluations and actions against Bresler, supported the inference of actual malice. However, the court held that the complaint did not contain sufficient factual allegations to establish actual malice or defeat common-law immunity for DeRossi.As a result, the Supreme Judicial Court affirmed the Superior Court's order as to Muster and DeRossi and reversed it as to Bowe, allowing the claims against Muster and Bowe to proceed while dismissing the claims against DeRossi. View "Bresler v. Muster" on Justia Law

Two minor sisters suffered severe harm while in the custody of the Department of Children and Families (DCF). In August 2015, the older sister, then twenty-two months old, manipulated a thermostat dial from her crib, causing the bedroom to overheat. This incident led to her permanent impairment and the death of another foster child. A lawsuit was filed in the Superior Court against several defendants, including four DCF employees, alleging that their failure to fulfill their duties caused the children's harm.The Superior Court denied the employees' motion for summary judgment, which argued they were entitled to qualified immunity. The employees appealed under the doctrine of present execution, and the Supreme Judicial Court transferred the case on its own motion.The Supreme Judicial Court concluded that the DCF employees did not violate the children's substantive due process rights, as their conduct was not the proximate cause of the harm suffered. The court held that the employees' omissions, such as failing to conduct more frequent home visits or investigate the presence of a potentially dangerous individual in the foster home, did not foreseeably lead to the children's injuries. Therefore, the employees were entitled to qualified immunity, and the Superior Court's denial of summary judgment was reversed. View "Gotay v. Creen" on Justia Law

The plaintiff, Matthew Theisz, was assaulted by an MBTA bus driver with a known history of anger management issues and prior violent incidents. The MBTA had hired, promoted, and retained the driver despite his problematic behavior, including a previous assault on a passenger and an arrest following a confrontation with a police officer. On the day of the incident, Theisz, lost and frustrated, attempted to get the driver's attention, leading to a violent altercation where the driver severely beat him, resulting in a traumatic brain injury.The Superior Court denied the MBTA's motion for summary judgment, which argued that it was immune from liability under the Massachusetts Tort Claims Act (MTCA), specifically G. L. c. 258, § 10 (j). The MBTA contended that the claim was based on a failure to prevent harm by a third person. The Appeals Court affirmed the denial, and the MBTA sought further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that § 10 (j) does not provide immunity to the MBTA for its own negligence in hiring, promoting, retaining, and supervising the bus driver. The court held that the MBTA's affirmative act of placing the driver in a public-facing position, despite his known violent tendencies, materially contributed to the harm suffered by Theisz. The court also reaffirmed that § 10 (c) of the MTCA, which provides immunity for intentional torts, does not shield the MBTA from liability for its own negligent supervision and retention of the driver. The court affirmed the denial of summary judgment and remanded the case for further proceedings. View "Theisz v. Massachusetts Bay Transportation Authority" on Justia Law

The plaintiff, the register of deeds for Norfolk County, filed a lawsuit against the county commissioners for Norfolk County, seeking declaratory, mandamus, and injunctive relief regarding funding and personnel matters within the registry of deeds. The dispute centered on hiring a new chief information officer and the funding for that position. While this litigation was ongoing, the plaintiff requested the county director to transfer funds within the registry's budget to cover legal fees for the personnel litigation. The county director denied these requests, prompting the plaintiff to file a second lawsuit for declaratory, mandamus, and injunctive relief.In the Superior Court, the plaintiff moved for summary judgment regarding the budget transfers, and the defendants cross-moved for summary judgment. The judge granted summary judgment in favor of the plaintiff, ruling that under G. L. c. 35, § 32, the plaintiff had the authority to transfer funds within a main group of the budget based on his opinion of public necessity and convenience. The defendants appealed this decision.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the Superior Court's decision. The court held that the statutory language of G. L. c. 35, § 32, clearly grants the authorized official the discretion to transfer funds within a main group based on their opinion of public necessity and convenience. The court found that the plaintiff's opinion was sufficient justification for the transfers and that the defendants' interference was unlawful. The court ordered that any outstanding amounts that should have been transferred be specifically authorized by the defendants and that the defendants refrain from hindering lawful transfers within the Contractual Services main group in the future. View "Register of Deeds for Norfolk County v. County Director for Norfolk County" on Justia Law

The taxpayer, 480 McClellan LLC, leased property from the Massachusetts Port Authority (Massport) to construct and operate a cargo facility. The property, located in East Boston, was previously taxable before Massport acquired it in 1990. In 2017, the City of Boston began taxing the property, and the taxpayer sought abatements for the tax years 2017 through 2020, which were denied by the city's board of assessors.The taxpayer appealed to the Appellate Tax Board, arguing that section 53 of the 1993 supplemental appropriations bill exempted it from taxation because the property was used for "air transportation purposes." The board invited the parties to address whether section 53 had amended section 17 of the Massport enabling act, which governs the taxation of Massport lessees. The board concluded that section 53 was not enacted because the Senate did not finalize its reconsideration of the Governor's veto before the end of the 1993 legislative session. The board also determined that the property was leased for "business purposes" under section 17, making the taxpayer subject to taxation.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the board's decision. The court held that the Senate's initial vote to override the Governor's veto of section 53 was not final due to a timely motion to reconsider, which was not resolved before the legislative session ended. Therefore, section 53 did not amend section 17. The court also upheld the board's interpretation that "business purposes" under section 17 includes commercial, for-profit activities, and found that the taxpayer leased the property for such purposes. Consequently, the taxpayer was subject to taxation under section 17. View "480 McClellan LLC v. Board of Assessors of Boston" on Justia Law