Justia Massachusetts Supreme Court Opinion Summaries

A laboratory director at the Whitehead Institute for Biomedical Research and a tenured professor at MIT met a graduate student who later became a fellow at Whitehead. During her academic progression, the professor made sexualized comments to her and later engaged in a sexual relationship with her, which she felt unable to end due to his influence over her career. After the relationship ended, he continued making inappropriate comments. A culture survey at Whitehead suggested that he fostered or participated in sexually explicit and inappropriate discussions and threatened those who reported his conduct. An independent investigation found he had violated Whitehead policies, including its sexual harassment policy, leading to his resignation and MIT placing him on leave.While MIT’s investigation was ongoing, the professor sued the student, Whitehead, and its director for defamation and other claims. The student filed a counterclaim against the professor for sexual harassment under the Massachusetts sexual harassment statute (G. L. c. 214, § 1C). The Superior Court dismissed this counterclaim, holding that the statute did not permit claims against individuals, only institutions. The Appeals Court affirmed, reasoning the statute only applied to educational institutions.The Supreme Judicial Court of Massachusetts granted further appellate review and considered whether the sexual harassment statute permits claims against individual perpetrators in the academic context. The court held that the statute does allow such claims, noting its plain language and remedial purpose. The court reversed the Superior Court’s dismissal of the counterclaim and remanded for further proceedings, explicitly holding that victims of sexual harassment in academic settings may bring actions against individual harassers under the statute. View "Sabatini v. Knouse" on Justia Law

The plaintiff, who served as chief of a town fire department, alleged that his employer retaliated against him in violation of state anti-discrimination law after he complained about the treatment of his niece, a probationary firefighter. The niece, along with another woman, was hired by the department, and concerns were raised by supervisors about her performance during training. The chief recused himself from her hiring and training processes due to potential conflicts of interest, but later advocated for her to receive remedial training, as had been provided to other male firefighters with similar deficiencies. After raising concerns about what he viewed as unfair treatment of his niece compared to male colleagues, the chief found himself subject to a series of adverse employment actions, including denial of a contract renewal, an internal investigation, administrative leave, and ultimately, circumstances that led to his resignation.Previously, the plaintiff filed federal claims, including retaliation and age discrimination, in the United States District Court for the District of Massachusetts. That court granted summary judgment for the town on all claims, and the United States Court of Appeals for the First Circuit affirmed as to the federal claims, but dismissed the remaining state law claims without prejudice. The plaintiff then refiled his state law claims in the Superior Court in Plymouth County. The Superior Court granted summary judgment to the town on some claims but allowed the retaliation claim to proceed to trial. A jury found for the plaintiff, awarding both compensatory and punitive damages. The trial judge denied the town’s motion for judgment notwithstanding the verdict or for a new trial.On further review, the Supreme Judicial Court of Massachusetts held that there was sufficient evidence for the jury to find that the town retaliated against the plaintiff for his complaints of gender discrimination. Although the jury instructions improperly blended pretext and mixed-motive frameworks, the Court determined that this did not prejudice the outcome, as the jury made clear findings on causation and intentional retaliation. The Court affirmed the judgment and the damages awarded to the plaintiff. View "Robinson v. Marshfield" on Justia Law

The plaintiff, a general laborer, sued his employer and its owner for violations of the Massachusetts Wage Act, alleging that he was not paid for four weeks of work. He sought damages for lost wages. The defendants denied the allegations and filed counterclaims against the plaintiff for abuse of process and malicious prosecution. In response, the plaintiff filed a special motion to dismiss the counterclaims under the Massachusetts anti-SLAPP statute, claiming the counterclaims were solely based on his act of petitioning the court to recover his wages.A judge in the Waltham Division of the District Court Department initially dismissed the counterclaims, but later reversed that decision after granting the defendants’ motion for reconsideration. The plaintiff then pursued an interlocutory appeal. The Massachusetts Appeals Court reversed the lower court’s decision and ordered the counterclaims dismissed under the anti-SLAPP statute. The Appeals Court subsequently considered the plaintiff’s unopposed petition for appellate attorney’s fees, which used the lodestar method to calculate a request of $67,361.25. Although the Appeals Court found the hours and rates reasonable, it reduced the award by half, reasoning that the fees were disproportionate to the relatively low monetary value of the underlying Wage Act claims.The Supreme Judicial Court of Massachusetts granted further appellate review, limited to the issue of appellate attorney’s fees. The court held that it was an abuse of discretion for the Appeals Court to reduce the fee award based on the value of the underlying Wage Act claims when the reasonableness of the hours and rates for the anti-SLAPP work had already been established. The Supreme Judicial Court therefore reversed the reduction and affirmed an award of $67,361.25 in appellate attorney’s fees for the anti-SLAPP work. View "Hidalgo v. Watch City Construction Corp." on Justia Law

An employee of a Massachusetts public college, serving as director of facilities and public safety, objected to the college’s failure to report a student’s sexual assault allegations as required under federal law. The employee, who was responsible for campus security and compliance with the federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act), learned that various college officials had been informed of the student’s allegations over several years, but the incidents were not reported to the U.S. Department of Education as required. The employee raised these concerns with State auditors and the chair of the college’s board of trustees. Subsequently, the college conducted internal and external investigations, which confirmed failures to report the incidents. The employee was later terminated, with the college citing performance deficiencies, including failure to comply with reporting obligations.The employee filed suit in the Massachusetts Superior Court, claiming wrongful termination in violation of the Massachusetts Whistleblower Act (MWA). On cross-motions for summary judgment, the Superior Court judge ruled that the employee engaged in protected activity under the MWA by objecting to the college’s failure to report as required by the Clery Act, but left the question of whether the employee’s whistleblowing or his own purported misconduct caused his termination for the jury. After trial, the jury found in the employee’s favor, awarding damages.The Supreme Judicial Court of Massachusetts reviewed whether the summary judgment ruling on protected activity was correct. The court held that, as a matter of law, an employee objecting to undisputedly unlawful activity—here, the failure to report as required by the Clery Act—engaged in protected activity under the MWA, even if the employee was involved in the underlying wrongdoing. The court affirmed the judgment, concluding the trial judge properly submitted the causation question to the jury. View "Galvin v. Roxbury Community College" on Justia Law

The plaintiff was employed as a senior director of finance at a data management software company, which later rebranded following a merger. Initially hired full time, the plaintiff’s position was later reduced to part time with a corresponding salary adjustment. Around this time, the plaintiff and the company entered into a retention bonus agreement, which provided for two bonus payments if the plaintiff remained employed and in good performance standing, with no reduction in work schedule, through two specified dates. The agreement also required the plaintiff to return the bonus if he left voluntarily or was terminated for cause before those dates. The plaintiff remained employed through both retention dates and received both bonus payments, though the second payment was made eight days after his termination due to a reduction in force.The plaintiff filed suit in the Concord Division of the District Court Department, asserting, among other claims, that the company violated the Massachusetts Wage Act by failing to pay the second retention bonus on his last day of employment. Both parties moved for summary judgment, which were denied without explanation. Upon reconsideration, a different District Court judge entered judgment for the defendants, finding that the retention bonus was not a “wage” under the Wage Act because it was contingent compensation. The Appellate Division of the District Court Department affirmed this decision, and the plaintiff sought further review.The Supreme Judicial Court of Massachusetts granted direct appellate review. It held that retention bonus payments conditioned on continued employment and other requirements are not “wages” under the Wage Act, but rather constitute additional, contingent compensation. The court affirmed the judgment in favor of the defendants, concluding that the Wage Act did not apply to the retention bonus payments at issue. View "Nunez v. Syncsort Incorporated" on Justia Law

An insurer, Arrowood Indemnity Company, entered run-off in 2003, ceasing to issue new policies but continuing to manage existing claims, including workers' compensation for a Scully Signal Company employee who sustained a second work-related injury in 2001. Arrowood sought second-injury reimbursements from the Massachusetts Workers' Compensation Trust Fund, which reimburses insurers for a portion of workers' compensation benefits paid to employees with exacerbated injuries. Arrowood and the Trust Fund settled in 2009, with Arrowood receiving reimbursements until 2013.The Department of Industrial Accidents (DIA) began denying Arrowood's reimbursement requests in 2015, citing a precedent that insurers in run-off, who no longer collect and transmit employer assessments to the Trust Fund, are ineligible for reimbursements. Arrowood's subsequent complaint in Superior Court was dismissed, and the Appeals Court affirmed the dismissal, directing Arrowood to seek administrative review. The DIA administrative judge and the Industrial Accident Reviewing Board upheld the denial, leading Arrowood to appeal to the Appeals Court.The Appeals Court reversed the Board's decision, ruling that the statutory language of the Massachusetts workers' compensation act does not preclude insurers in run-off from receiving second-injury reimbursements. The Supreme Judicial Court of Massachusetts granted further appellate review and agreed with the Appeals Court. The Court held that the plain language of the act does not exclude insurers in run-off from reimbursement eligibility and that the statutory scheme supports this interpretation. The Court reversed the Board's decision and remanded for further proceedings consistent with its opinion. View "Arrowood Indemnity Company v. Workers' Compensation Trust Fund" on Justia Law

Susan Miele was hired by Foundation Medicine, Inc. (FMI) in 2017 and signed a restrictive covenant agreement that included a nonsolicitation provision. In 2020, Miele and FMI executed a transition agreement upon her separation, which incorporated the restrictive covenant agreement and included a forfeiture clause. FMI paid Miele approximately $1.2 million in transition benefits. After joining Ginkgo Bioworks in 2021, Miele allegedly solicited FMI employees to join Ginkgo, leading FMI to cease further payments and demand repayment of benefits.Miele sued FMI in late 2021 for breach of the transition agreement, and FMI counterclaimed for breach of contract. Miele moved for judgment on the pleadings, arguing that the provisions FMI relied on were unenforceable under the Massachusetts Noncompetition Agreement Act. A Superior Court judge granted Miele's motion in part, ruling that FMI could not enforce the forfeiture provision but allowed FMI to assert Miele's breach as a defense and seek damages. The judge concluded that the transition agreement qualified as a "forfeiture for competition agreement" under the act.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the Massachusetts Noncompetition Agreement Act does not apply to a nonsolicitation agreement, even if it includes a forfeiture provision. The court reasoned that the act explicitly excludes nonsolicitation agreements from its scope, and a forfeiture clause does not change this exclusion. The court reversed the Superior Court's order partially granting Miele's motion for judgment on the pleadings and remanded the matter for further proceedings consistent with its opinion. View "Miele v. Foundation Medicine, Inc." 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

Sergeant John Babcock, a member of the Newton police department, was transferred from his position as a traffic sergeant with regular daytime hours to a night shift sergeant position. This transfer occurred after Babcock had been actively involved in union activities, including disputes with the police chief, David MacDonald. Despite receiving an eight percent pay increase as stipulated in the collective bargaining agreement (CBA), Babcock's new position required him to work irregular nighttime hours, weekends, and holidays, which he claimed negatively impacted his family life.The Commonwealth Employment Relations Board (CERB) reviewed the case after the union filed a charge of prohibited practice, alleging that the transfer was retaliatory. The hearing officer initially found that while the transfer was an adverse employment action and the union had established a prima facie case of retaliation, the city had rebutted this by producing evidence of Babcock's insubordination and misconduct. The hearing officer concluded that the city's reasons for the transfer were legitimate and dismissed the complaint.Upon appeal, the CERB disagreed with the hearing officer's conclusion, finding that the city failed to produce evidence that Babcock's misconduct was the reason for his transfer. The CERB determined that the transfer was indeed retaliatory and ordered that Babcock be reinstated to his previous position.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the CERB's decision. The court held that Babcock's transfer constituted an adverse employment action despite the pay increase, as it resulted in a material disadvantage in the terms and conditions of his employment. The court also concluded that a generally good work record is not a necessary element to establish a prima facie case of retaliation. The city's failure to produce evidence linking Babcock's misconduct to the transfer decision meant that the union's prima facie case of retaliation remained unrebutted. View "City of Newton v. Commonwealth Employment Relations Board" on Justia Law

Jeff Stacy, a lineman for Unitil Corporation, continued working during the COVID-19 pandemic as his job was classified as an essential service. Despite the Governor's orders to shut down nonessential businesses, Stacy worked closely with colleagues, which led to his exposure to the virus. In February 2021, after working overtime during snowstorms, Stacy contracted COVID-19 from a coworker, resulting in severe illness and total disability. He applied for workers' compensation benefits, which were initially denied by his employer's insurer, Travelers Indemnity Company of Connecticut.An administrative judge from the Department of Industrial Accidents held an evidentiary hearing and ruled in favor of Stacy, finding that the risk of contracting COVID-19 was inherent in his employment during the pandemic. The judge noted that Stacy's job required close physical proximity to coworkers, increasing his risk of infection. The Industrial Accident Reviewing Board affirmed the judge's decision, adopting the factual findings and concluding that the decision was supported by adequate evidence and reasoned decision-making.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the board's decision. The court held that the board's determination that the risk of contracting COVID-19 was inherent in Stacy's employment was not arbitrary or capricious. The court emphasized that Stacy's role as an essential worker, who continued to work closely with others during a time when most businesses were closed and social distancing was mandated, justified the finding that his employment posed a unique risk of infection. Thus, Stacy's claim for workers' compensation benefits was upheld. View "Stacy's Case" on Justia Law