Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Labor & Employment Law
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In this interlocutory appeal, the Supreme Judicial Court affirmed the judgment of the superior court judge denying the Commonwealth's motion for summary judgment on Plaintiff's complaint alleging wrongful termination under Mass. Gen. Laws ch. 149, 185, the Massachusetts whistleblower act, holding that there was no error.In 2014, Governor Deval Patrick dismissed Plaintiff from her position as chair of the Sex Offender Registry Board (SORB), stating to the media that Plaintiff had improperly interfered in a sex offender classification proceeding and had attempted inappropriately to influence the hearing examiner. Plaintiff brought this complaint against Patrick for defamation and against the Commonwealth for wrongful termination. The claims against Patrick were dismissed, but the superior court denied the Commonwealth's motion for summary judgment on the remaining whistleblower claim. The Supreme Court affirmed, holding that genuine issues of material fact remained in dispute, precluding summary judgment in favor of the Commonwealth. View "Edwards v. Commonwealth" on Justia Law

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The Supreme Judicial Court reversed the order of the trial court dismissing Plaintiff's complaint with respect to all counts in the complaint with the exception of the public policy claim, holding that Plaintiff's complaint stated a claim for which relief may be granted.Plaintiff filed a complaint against the Children's Hospital Corporation (CHC) under the Domestic Violence and Abuse Leave Act (DVLA), Mass. Gen. Laws ch. 149, 52E, alleging that it terminated her employment after she disclosed to CHC that her abuser had violated the terms of a harassment prevention order and that Plaintiff had reported the violation to the police. Plaintiff further asserted that her termination contravened the Commonwealth's public policy to protect victims of abusive behavior. The trial court allowed CHC's motion to dismiss. The Supreme Judicial Court affirmed in part and reversed in part, holding (1) Plaintiff's complaint stated a ground upon which relief could be granted; and (2) a public policy ground for relief was unavailable. View "Osborne-Trussell v. Children's Hospital Corp." on Justia Law

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The Supreme Judicial Court held that the term "service charge" is a defined term in the Tips Act, Mass. Gen. Laws ch. 149, 152A, that the disputed charge at issue in this case was properly characterized as a "service charge," and that the "safe harbor" provision of the Act did not apply in this case.Plaintiffs, service employees for Concert Blue Hill, LLC and its managerial staff (collectively, Blue Hill), alleged that Blue Hill violated the Act by failing to remit to them charges identified as "service" charges on invoices sent to patrons but previously described in initial documents as "administrative" or "overhead" charges. The superior court granted Blue Hill's motion for judgment on the pleadings and dismissed the action. The Appeals Court affirmed. The Supreme Judicial Court reversed, holding that the plain meaning of the Act required Blue Hill to remit the disputed charge to Plaintiffs. View "Hovagimian v. Concert Blue Hill, LLC" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the superior court affirming the decision of the Civil Service Commission ordering Plaintiff's reinstatement to his position as a tenured civil service employee, holding that the Commission's determination that the Town of Brookline lacked just cause to discharge Plaintiff was supported by substantial evidence.Specifically, the Supreme Judicial Court held (1) in analyzing whether an employee was fired without just cause, in violation of basic merit principles, the Commission can consider evidence of discriminatory or retaliatory conduct that is generally addressed in the context of a claim under Mass. Gen. Laws ch. 151B; and (2) the Commission did not exceed its authority or lacked substantial evidence in determining that the Town lacked substantial evidence for its decision. View "Town of Brookline v. Alston" on Justia Law

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The Supreme Judicial Court vacated the portion of the trial court's judgment denying Plaintiff's claim under Mass. Gen. Laws ch. 93A, 11 and affirmed the remainder of the judgment, holding that the judge erred in instructing the jury under section 11.The attorney defendants in this case misappropriated propriety materials from their employer during their employment and subsequently used those materials to compete with their former employer. A jury found Defendants liable on claims for conversion, conspiracy, and breach of the duty of loyalty. The jury denied relief on the plaintiff employer's claims for unfair or deceptive trade practices, in violation of section 11. The Supreme Judicial Court vacated the judgment in part, holding that Defendants may be liable for unfair or deceptive trade practices, and the judge erred in instructing the jury that Defendants' conduct before leaving their employer was not relevant to Plaintiff's claim under section 11. View "Governo Law Firm LLC v. Bergeron" on Justia Law

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The Supreme Judicial Court held that the ministerial exception did not apply to Plaintiff, an associate professor of social work at a private Christian liberal arts college, and therefore, the superior court judge did not err in dismissing on summary judgment Gordon College's affirmative defense of the ministerial exception in this retaliation complaint.The ministerial exception prohibits government interference with employment relationships between religious institutions and their ministerial employees. Plaintiff, a tenured associate professor of social work at Gordon, alleged that Defendants - Gordon and its president and provost (collectively, Gordon) - unlawfully retaliated against her for her opposition to Gordon's policies and practices regarding LGBTQ+ individuals. The parties cross-moved for summary judgment on the question of whether the ministerial exception barred Plaintiff's claims. The superior court allowed Plaintiff's motion but denied Gordon's, concluding that Gordon was a religious institution but that Plaintiff was not a ministerial employee. The Supreme Judicial Court affirmed, holding that the superior court judge did not err in dismissing the affirmative defense of the ministerial exception. View "DeWeese-Boyd v. Gordon College" on Justia Law

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The Supreme Judicial Court vacated the decision of the reviewing board of the Department of Industrial Accidents determining that the Department lacked subject matter jurisdiction over the claim of Mark Mendes, holding that the Commonwealth had jurisdiction over Mendes's claim.Mendes, a Massachusetts resident, entered into an employment contract, performed much of the work, and was injured outside of the Commonwealth. The Department's reviewing board denied and dismissed Mendes's claim for workers' compensation, determining that Massachusetts lacked jurisdiction over the claim because it was neither the place of hire nor the place of injury. The Supreme Judicial Court vacated the board's decision, holding that there were sufficient significant contacts between Massachusetts and Mendes's employment such that the employment relationship was located in Massachusetts. View "Mark Mendes's Case" on Justia Law

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The Supreme Judicial Court affirmed the decision of the reviewing board of the Department of Industrial Accidents (department) concluding that marijuana's status as a federally illicit substance preempted any state level authority to order a workers' compensation insurer to pay for Daniel Wright's medical marijuana expenses, holding that the workers' compensation insurer in this case could not be required to pay for medical marijuana expenses.Wright sought compensation for $24,267 of medical marijuana expenses to treat chronic pain stemming from two work-related injuries. An administrative judge denied his claim, and the reviewing board affirmed. The Supreme Judicial Court affirmed, holding that the reimbursement limitation provision contained within the Commonwealth's medical marijuana act, St. 2012, c. 369, 7, prevents a health insurance provider or government agency from being ordered to reimburse a claimant for medical marijuana expenses. View "Daniel Wright's Case" on Justia Law

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The Supreme Judicial Court affirmed the decision of the superior court affirming the decision of the Contributory Retirement Appeal Board (CRAB) that Appellant was not entitled to retirement benefits calculated based on her salary for the years that she worked as a contract employee, holding that the superior court did not abuse its discretion.After Appellant retired she requested that her benefit amount be based on her compensation during the purchased years of creditable contract employment with the State rather than her lower-paid years as a regular State employee. CRAB ruled against Appellant's request, and the superior court affirmed. The Supreme Court affirmed, holding (1) Appellant did not meet the statutory definition of "employee" for purposes of the retirement system in the years that she worked as a contract employee; and (2) therefore, CRAB properly determined that compensation received during years for which credit in the State retirement system is purchased is not regular compensation and may not be used to calculate a member's pension benefit. View "Young v. Contributory Retirement Appeal Board" on Justia Law

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The Supreme Judicial Court reversed the order granting judgment to Plaintiffs on their claims under the Wage Act, Mass. Gen. Laws ch. 149, 148, 150, and the Prevailing Wage Act, Mass. Gen. Laws ch. 149, 26-27H, on the ground that by violating the Prevailing Wage Act, Defendants violated the Wage Act as well, holding that Plaintiffs may not avoid the limitations that the Prevailing Wage Act places on their recovery by pursuing an otherwise duplicative claim under the Wage Act.Plaintiffs asserted that for several years they were paid less than the wages required by the Prevailing Wage Act. The motion judge granted partial summary judgment for Plaintiffs, concluding that Defendants' "chronic underpayment" of Plaintiffs constituted a plain violation of the Prevailing Wage Act and that Defendants' failure to pay Plaintiffs at the prescribed wage rates also constituted a violation of the Wage Act. The Supreme Judicial Court reversed the order allowing Plaintiffs' motion for partial summary judgment, holding that, whereas the Prevailing Wage Act and the Wage Act provide conflicting mechanisms to recover the same underpayment of wages, Plaintiffs may, in this instance, recover solely under the Prevailing Wage Act. View "Donis v. American Waste Services, LLC" on Justia Law