Justia Massachusetts Supreme Court Opinion Summaries

Employee was severely injured while traveling abroad on a business trip. Employer had purchased two workers’ compensation policies from two different insurers, the Insurance Company of the State of Pennsylvania (ISOP) and Great Northern Insurance Company (Great Northern). Both policies provided primary coverage. Employee pursued a workers’ compensation claim. Employer gave notice of the claim only to ISOP. ISOP began making payments pursuant to the policy and defended the claim. When ISOP learned that Employer also had workers’ compensation coverage under its Great Northern policy, ISOP filed a complaint against Great Northern seeking a judgment declaring that the doctrine of equitable contribution required Great Northern to pay one-half of the past and future defense costs and indemnity payments related to Employer’s claim. A federal district court granted summary judgment for Great Northern. ISOP appealed, and the United States Court of Appeals for the First Circuit certified a question to the Supreme Court. The Court answered that, where two primary workers’ compensation insurance policies provide coverage for the same loss arising from an injury to an employee, the insurance company that pays that loss has a right of equitable contribution from the coinsurer, regardless of whether the insured gives notice of the injury only to one insurer. View "Ins. Co. of State of Penn. v. Great N. Ins. Co." on Justia Law

Plaintiff, a black male of African descent who had a medical degree from the University of the West Indies, was terminated from his employment with Mount Auburn Hospital while completing the first year of his residency. Plaintiff filed a ten-count complaint against the Hospital and three physicians who supervised his work, asserting employment discrimination and breach of contract, among other claims. The Appeals Court reversed as to the discrimination and breach of contract claims. The Supreme Judicial Court vacated the judgments in favor of Defendants on Plaintiff’s claims for employment discrimination and breach of contract, holding that Defendants were not entitled to summary judgment and that Plaintiff presented sufficient evidence to allow a jury to hear his claims. View "Bulwer v. Mount Auburn Hospital" on Justia Law

Two employees were injured in the course of their employment, collected workers’ compensation benefits and then reached settlement agreements with third parties including damages for their pain and suffering. The same insurer insured by employers and sought reimbursement from the employees’ recoveries. In one employee’s case, the superior court judge rejected a settlement agreement providing that the insurer would not have a lien on the damages for pain and suffering. In the second employee’s case, a superior court judge approved a settlement agreement similar to the agreement rejected by the judge in the first employee’s case. The Appeals Court determined that the employees’ awards for pain and suffering were exempt from the insurer’s liens. The Supreme Judicial Court combined the two cases for argument and held that an insurer’s lien does not extend to damages allocated to an employee’s pain and suffering. View "DiCarlo v. Suffolk Constr. Co., Inc. v. Angelini Plastering, Inc." on Justia Law

EventMonitor, Inc. terminated the employment of Anthony Leness, characterizing the termination as “without cause.” After discovering that Leness had copies the data on a company laptop computer EventMonitor retroactively characterized the termination as having been for cause and stopped paying Leness any severance payments. EventMonitor filed suit against Leness, alleging breach of contract, breach of the covenant of good faith and fair dealing, and breach of fiduciary duty. Leness counterclaimed for breach of contract, breach of the covenant of good faith and fair dealing, and violations of the Wage Act. A superior court judge entered judgment for Leness on EventMonitor’s claims and Leness’s counterclaims, finding that Leness had not engaged in defalcation of EventMonitor’s assets and had not committed a material breach of the employment contract, and thus that his termination could not have been for cause. The Supreme Judicial Court affirmed, holding (1) the trial judge correctly found that Leness did not commit a material breach of the employment contract and did not engage in defalcation of company assets, and therefore, Leness committed no act giving rise to a termination for cause; and (2) the trial judge correctly concluded that Leness was entitled to severance payments under the terms of the contract. View "EventMonitor, Inc. v. Leness" on Justia Law

The town of Randolph bypassed Plaintiff, a police officer with the town, and appointed three candidates with lower scores on the police sergeant’s examination to its three open police sergeant positions. Plaintiff appealed. The Civil Service Commission dismissed the appeal. Plaintiff sought review of the Commission’s decision in the superior court. A superior court judge denied Plaintiff’s motion for reconsideration and entered judgment for the Commission. The Supreme Judicial Court affirmed the superior court’s denial of Plaintiff’s motion for judgment on the pleadings, holding (1) the record did not support the concern that the town’s flawed procedure for selecting candidates reflected a departure from basic merit principles; and (2) there was substantial evidence to support a reasonable justification for the town’s bypass. View "Sherman v. Town of Randolph" on Justia Law

The Town of Hanover decided to bypass Plaintiff, a police officer with the town, and appoint two candidates with lower scores on the police sergeant’s examination to its open police sergeant positions. Plaintiff appealed the town’s decision to the Civil Service Commission, arguing that, pursuant to Mass. Gen. Laws ch. 31, 2(b), where an appointing authority promotes a candidate other than the candidate ranked highest on the certification list, the promotion is not effective until the appointing authority’s statement of reasons for the bypass have been “received by the administrator” and that the administrator may not delegate that function to the town’s appointing authority. The Commission denied the appeal. A superior court judge allowed Plaintiff’s motion for judgment on the pleadings and and remanded the matter to the human resources division (HRD) to decide whether the bypass reasons should be approved. The Supreme Judicial Court vacated the judgment and remanded, holding (1) the administrator may delegate its administrative function to receive statements of reasons supporting bypass promotions, and it was practicable to do so in this case; and (2) the judge erred in remanding the matter to the HRD without conducting his own review of whether the Commission’s determination was supported by substantial evidence. View "Malloch v. Town of Hanover" on Justia Law

Plaintiff, a male, was a candidate for the December, 2010 police academy class. When Plaintiff was not admitted, he brought a claim of sex discrimination against the Boston Police Department and the Commonwealth’s Human Resources Division, alleging discrimination arising from the Department’s preferential treatment of females in hiring candidates. The superior court granted summary judgment in favor of the Department, concluding that the preferential treatment of female candidates was justified because “gender was a valid bona fide occupational qualification.” The Supreme Judicial Court vacated the judgment of the superior court and remanded the case for entry of a judgment of dismissal for lack of standing, holding that the alleged injury was not sufficiently concrete and imminent so as to confer proper standing on Plaintiff. View "Pugsley v. Police Dep’t of Boston" on Justia Law

Plaintiff, a male, was a candidate for the December, 2010 police academy class. When Plaintiff was not admitted, he brought a claim of sex discrimination against the Boston Police Department and the Commonwealth’s Human Resources Division, alleging discrimination arising from the Department’s preferential treatment of females in hiring candidates. The superior court granted summary judgment in favor of the Department, concluding that the preferential treatment of female candidates was justified because “gender was a valid bona fide occupational qualification.” The Supreme Judicial Court vacated the judgment of the superior court and remanded the case for entry of a judgment of dismissal for lack of standing, holding that the alleged injury was not sufficiently concrete and imminent so as to confer proper standing on Plaintiff. View "Pugsley v. Police Dep’t of Boston" on Justia Law

Defendants in this case were licensed Massachusetts real estate brokerage firms and some of their members and shareholders. Defendants classified Plaintiffs, licensed real estate salespersons, as independent contractors. Plaintiffs filed a complaint alleging, inter alia, that Defendants violated the independent contractor statute by not classifying Plaintiffs as employees. On this count of the complaint, the trial judge granted partial summary judgment in favor of Defendants, concluding that the independent contractor statute did not control under these circumstances to the salespersons in this industry. The Supreme Judicial Court affirmed, holding that the superior court judge did not err in concluding that the independent contractor statute does not apply to real estate salespersons. View "Monell v. Boston Pads, LLC" on Justia Law

Plaintiffs in these consolidated cases leased taxicabs and licenses, called “medallions,” for each taxicab. Plaintiffs claimed that they were employees of certain taxicab owners, radio associations, and a taxicab garage (collectively, Defendants) but were misclassified as independent contractors. Defendants argued that their relationships with Plaintiffs must be considered in the context of a municipal regulation (Rule 403), which explicitly permits drivers to operate as independent contractors. Plaintiffs argued that the municipal regulation could not override the independent contractor statute, under which an individual performing any service is presumed to be an employee. The superior court concluded that Plaintiffs provided a service to Defendants but denied summary judgment on the grounds that genuine issues of material fact existed as to whether the provision of taxi services was within the usual course of Defendants’ businesses. The Supreme Judicial Court vacated the lower court’s order, holding (1) Rule 403 is not contrary to the policies undergirding the independent contractor statute; and (2) because the the medallion owners and radio associations had, in complying with Rule 403, satisfied each prong of the independent contractor test, summary judgment should have been granted to those defendants on count one of the complaints, misclassification as independent contractors. View "Sebago v. Boston Cab Dispatch, Inc." on Justia Law