Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Government & Administrative Law
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In this case, the Supreme Judicial Court of Massachusetts was called upon to determine which law applied to the sealing of records from youthful offender proceedings - G. L. c. 276, § 100A, the adult criminal record sealing statute or G. L. c. 276, § 100B, the juvenile delinquency sealing statute. The case arose when the Commissioner of Probation denied the petitioner's request to have his youthful offender records sealed under § 100B and instead applied the adult criminal record sealing statute, § 100A.The court, after examining both statutes and considering the legislative intent, concluded that § 100B, the juvenile delinquency sealing statute, was the proper statute for the sealing of records of youthful offenders. The court found that the Legislature’s intent to aid, encourage, and guide juveniles, which includes youthful offenders, was more consistent with the process outlined in § 100B.The court held that it was an error for the Commissioner of Probation to refuse to seal the petitioner's Juvenile Court records under § 100B, as the petitioner had satisfied all the requirements under the statute. Therefore, the case was remanded back to the county court for the entry of a judgment in favor of the petitioner. View "In the Matter of an Impounded Case" on Justia Law

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In this case, several residents of the town of Norwell, Massachusetts filed a lawsuit to compel the town's select board to transfer municipal land to the town's conservation commission. The select board had previously designated the land for the development of affordable housing. The main issue on appeal was whether the land was "held by a city or town . . . for a specific purpose" under Massachusetts General Laws Chapter 40, Section 15A. The Supreme Judicial Court of Massachusetts affirmed the Land Court's grant of summary judgment in favor of the select board. The Supreme Judicial Court held that town-owned land is held for a specific municipal purpose under Massachusetts General Laws Chapter 40, Section 15A, where the totality of the circumstances indicates a clear and unequivocal intent by the town to hold the land for such purpose. Applying this totality of the circumstances test, the court found no material dispute of fact regarding the town's intent to dedicate the municipal land at issue for the purpose of affordable housing. Therefore, the court concluded that the allowance of summary judgment for the select board was correct. View "Carroll v. Select Board of Norwell" on Justia Law

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In the case at hand, the plaintiff, a civilly committed sexually dangerous person, petitioned the Department of Correction (DOC) for medical parole due to his deteriorating health conditions. The DOC denied his petition based on their policy that civilly committed individuals are ineligible for medical parole under G. L. c. 127, § 119A. The plaintiff sought review of this denial, arguing that his due process rights had been violated. A Superior Court judge allowed his motion for judgment on the pleadings and ordered the DOC to conduct a hearing on the plaintiff's medical parole petition.However, the Supreme Judicial Court of Massachusetts reversed the judge's order. The court held that the medical parole statute applies only to committed offenders serving a criminal sentence, not to civilly committed sexually dangerous persons. It further held that sexually dangerous persons may seek release due to terminal illness or physical or mental incapacity under G. L. c. 123A, § 9, and denying them an additional avenue for relief by means of the medical parole statute does not offend substantive due process. The Court concluded that the plaintiff's due process rights were not violated by the DOC's policy that precludes civilly committed sexually dangerous persons from eligibility for medical parole. View "Murphy v. Commissioner of Correction" on Justia Law

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The Supreme Judicial Court affirmed the decision of the superior court judge dismissing the underlying declaratory judgment complaint in this declaratory judgment action regarding the scope of the Department of Housing and Community Development's (DHCD) authority under Mass. Gen. Laws ch. 121B, 7A, holding that dismissal was warranted.Plaintiffs - location housing authorities (LHAs) of various cities and towns, current and former executive directors of LHAs and others - sought a judgment declaring that DHCD exceeded its authority under Mass. Gen. Laws ch. 121B, 7A by promulgating guidelines that govern contracts between an LHA and its executive director and making compliance with the guidelines a requirement to obtain contractual approval from DHCD. A superior court judge allowed DHCD's motion to dismiss. The Supreme Judicial Court affirmed, holding that LHAs have authority to hire executive directors and "determine their qualifications, duties, and compensation, under Mass. Gen. Laws ch. 121B, 7. View "Fairhaven Housing Authority v. Commonwealth" on Justia Law

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The Supreme Judicial Court held that an agreement entered into between Plaintiff Anthony Gattineri and Defendants Wynn MA, LLC and Wynn Resorts, Limited (collectively, Wynn) in San Diego California (the San Diego agreement) was unenforceable for reasons of public policy.Wynn entered into an option contract with FBT Everett Realty, LLC (FBT) to purchase a parcel of property. As Wynn's application for a casino license proceeded, the Massachusetts Gaming Commission discovered that there was a possibility of concealed ownership interests in FBT by a convicted felon with organized crime connections. In response, FBT lowered the purchase price for the parcel. The Commission approved the amended option agreement. Gattineri, a minority owner of FBT, opposed the price reduction and refused to sign the certificate required by the Commission. Gattineri alleged that at the San Diego meeting Wynn had agreed to pay Gattineri an additional $19 million in exchange for Gattineri signing the certificate. After the Commission awarded Wynn a casino license Gattineri brought suit claiming breach of the San Diego agreement because Wynn never paid Gattineri the promised $19 million. The Supreme Judicial Court held (1) the agreement was deliberately concealed from the Commission and inconsistent with the terms approved by the Commission; and (2) enforcement of such a secret agreement constituted a clear violation of public policy. View "Gattineri v. Wynn MA, LLC" on Justia Law

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The Supreme Judicial Court held that the Secretary of the Commonwealth did not overstep the bounds of the authority granted to him under the Massachusetts Uniform Securities Act (MUSA), Mass. Gen. Laws ch. 110A, by promulgating the "fiduciary duty rule."The Secretary brought an administrative enforcement proceeding alleging that Plaintiff Robinhood Financial LLC violated the prohibition in Mass. Gen. Laws ch. 110A, 204(a)(2)(G) against "unethical or dishonest conduct or practices in the securities, commodities or insurance business" by dispensing ill-suited investment advice to unsophisticated investors. The Secretary defined the phrase in section 204(a)(2)(G) to require broker-dealers that provide investment advice to retail customers to comply with a statutorily-defined fiduciary duty. Thereafter, Plaintiff brought the instant action challenging the validity of the fiduciary duty rule. The superior court concluded that the Secretary acted ultra vires to promulgating the rule. The Supreme Judicial Court reversed, holding (1) the Secretary acted within his authority under MUSA; (2) the fiduciary rule does not override common-law protections available to investors; (3) MUSA is not an impermissible delegation of legislative power; and (4) the fiduciary rule is not invalid under the doctrine of conflict preemption. View "Robinhood Financial LLC v. Secretary of the Commonwealth" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court judge granting summary judgment in favor of BSC Companies, Inc., BSC Group, Inc., and the companies' president (collectively, BSC) in this action brought by BSC's former employees alleging claims under the Prevailing Wage Act, Mass. Gen. Laws ch. 149, 26-27H, holding that the contracts at issue were not governed by the Act, and BSC was not required to pay its employees a prevailing wage pursuant to the contracts.At issue were two professional engineering services contracts awarded by the Department of Transportation (MassDOT) to BSC. The contracts were not competitively bid and were not awarded to the lowest bidder, unlike contracts for public works construction projects governed by the Act. Further, the contracts did not specify that BSC's employees would be paid at least a prevailing wage determined by the Department of Labor Standards. The superior court judge granted summary judgment to BSC. The Supreme Court affirmed, holding that Plaintiffs were not entitled to a prevailing wage for their work under the professional services contracts. View "Metcalf v. BSC Group, Inc." on Justia Law

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The Supreme Judicial Court remanded this matter involving the decision of the Planning Board of Monterey to deny Appellant's application to build an RV camp on the grounds of its Monterey property on the basis that the RV camp would not be an exempt religious use under the terms of the Dover Amendment, Mass. Gen. Laws ch. 40A, 3, holding that the proposed RV park would be an exempt religious use.Appellant, a nonprofit Christian organization that operated a camp in Monterey providing chapel sessions and religious instruction, applied to build an RV camp on the grounds of its property to house families who attend camp sessions. The Board denied the application, concluding that the RV camp was not a customary religious use and should not fall under the umbrella of the Dover Amendment. The Supreme Court remanded the case, holding (1) the primary or dominant purpose of the trailer park was a religiously significant goal; and (2) therefore, the proposed RV camp would be an exempt use under the Dover Amendment. View "Hume Lake Christian Camps, Inc. v. Planning Bd. of Monterey" on Justia Law

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The Supreme Judicial Court affirmed the judgment of a single justice of the court dismissing as moot Father's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that there was no abuse of discretion.The Department of Children and Families filed a care and protection petition pursuant to Mass. Gen. Laws ch. 119, 24 after the child in this case tested positive at birth for drugs. Thereafter, temporary custody was granted to Father. Father filed a motion to dismiss the petition for temporary custody on the grounds that there was no need for judicial intervention. The judge denied the order. Thereafter, Father brought his Mass. Gen. Laws ch. 211, 3 petition. While the petition was pending, the juvenile court dismissed the care and protection case. On that basis, the single justice dismissed Father's as moot Mass. Gen. Laws ch. 211, 3 petition. The Supreme Judicial Court affirmed, holding that this Court declines to exercise its discretion to consider Father's appeal notwithstanding the fact that it was moot. View "In re Care & Protection of a Minor" on Justia Law

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The Supreme Judicial Court affirmed the judgments of probation entered in separate superior court cases stemming from the same adjudication, holding that the State proved by a preponderance of the evidence that Defendant had violated the terms and conditions of his probation.After a hearing, the hearing justice found that Defendant had violated the terms of his probation in two cases and removed three and a half years suspension on each sentence in those cases. On appeal, Defendant argued that the State did not prove by a preponderance of the evidence that he violated the terms and conditions of his probation. The Supreme Judicial Court affirmed, holding that the hearing justice did not act arbitrarily or capriciously in finding a violation. View "Carver v. Commissioner of Correction" on Justia Law