Justia Massachusetts Supreme Court Opinion Summaries

The Lexington school district superintendent dismissed Mark Zagaeski, a Lexington high school teacher, from his position for conduct unbecoming a teacher. Zagaeski timely filed an appeal from the school district’s dismissal decision, which resulted in arbitration proceedings. The arbitrator (1) concluded that the school district carried its burden to show facts amounting to conduct unbecoming a teacher but that Zagaeski’s conduct only “nominally” constituted a basis for dismissal; and (2) reinstated Zagaeski as a teacher on the basis of “the best interests of the pupils.” The superior court confirmed the arbitrator’s award. The Supreme Judicial Court reversed the decision of the superior court judge and vacated the arbitration award, holding that, under the facts of this case, the arbitrator exceeded the scope of his authority by awarding Zagaeski's reinstatement. View "Sch. Comm. of Lexington v. Zagaeski" on Justia Law

Patricia Campatelli, the Register of Probate and Insolvency for Suffolk County, was suspended with pay pending further investigation of allegations of inappropriate conduct and mismanagement in the performance of her duties. Campatelli filed a complaint in the county court seeking a judgment declaring that the three court officials who placed her on administrative leave did not possess the authority to suspend her pursuant to Mass. Gen. Laws ch. 211, 4. The Supreme Judicial Court affirmed, holding that the Chief Justice of the Probate and Family Court Department, the Chief Justice of the Trial Court, and the Court Administrator possessed the authority to suspend Campatelli with pay. View "Campatelli v. Chief Justice of the Trial Court" on Justia Law

Selmark Associates, Inc. and Marathon Sales, Ltd. were closely held Massachusetts corporations that operated manufacturer’s representative companies. In 2001, Evan Ehrlich entered into a series of written agreements providing for the gradual sale of Marathon to Selmark and Ehrlich. Ehrlich subsequently became an employee and minority shareholder of Marathon. After Marathon and Selmark’s then-sole shareholder, David Elofson, terminated Ehrlich’s employment with Marathon, Ehrlich took a job with Tiger Electronics, a competing manufacturer’s representative company, where Ehrlich attempted to solicit several Marathon principals’ business. In 2008, Selmark and Marathon filed a breach of fiduciary complaint against Ehrlich. In response, Ehrlich asserted several counterclaims against Selmark, Marathon, and Elofson. The fury found (1) Ehrlich breached his fiduciary duties to Marathon by soliciting and acquiring Marathon principals for Tiger; (2) Selmark and Elofson committed a breach of contract to Ehrlich and breached their fiduciary duties to Ehrlich; and (3) all the Selmark parties engaged in unfair or deceptive acts or practices. The Supreme Judicial Court (1) affirmed the jury verdict in favor of Selmark and Marathon on their breach of fiduciary duty claim against Ehrlich; (2) affirmed the verdict in favor of Ehrlich on his breach of fiduciary duty counterclaim against Selmark and Elofson; (3) concluded that Ehrlich was entitled to recover on his breach of contract counterclaim but vacated the award of damages and remanded for a new trial on the issue of contractual damages; and (4) concluded that Ehrlich was not entitled to recover under Mass. Gen. Laws ch. 93A. View "Selmark Assocs., Inc. v. Ehrlich" on Justia Law

Stephanie Moulton was employed as a residential treatment counselor at North Suffolk Mental Health Association, Inc. when she was assaulted by DeShawn Chappell, one of the facility’s residents, causing her death. Moulton’s estate brought an action against the directors of North Suffolk, among other defendants, asserting claims for wrongful death and breach of fiduciary duty. The director defendants moved to dismiss the complaint on the grounds that (1) with respect to the wrongful death action, they were immune from suit, as Moulton’s employer, under the exclusive remedy provision of the Workers’ Compensation Act (Act); and (2) with respect to the breach of fiduciary duty claim, they owed Moulton no such duty. The superior court denied the director defendants’ motion to dismiss. The Supreme Judicial Court vacated the superior court’s judgment, holding (1) the director defendants were immune from suit under the exclusive remedy provision of the Act for the injuries Moulton sustained while acting within the course of her employment; and (2) the directors, as Moulton’s employer, owed no fiduciary duty to their employee. Remanded for an entry of judgment for the director defendants on all claims. View "Estate of Moulton v. Puopolo" on Justia Law

The Attorney General issued four citations to Plaintiffs for failing to pay the prevailing wage to certain employees. Plaintiffs appealed the citations to the Division of Administrative Law Appeals (DALA) under Mass. Gen. Laws ch. 149, 27C(b)(4). Kimberly Fletcher, a DALA administrative magistrate, heard Plaintiffs’ appeal but resigned before DALA issued a decision on the appeal. Shelly Taylor, the chief administrative magistrate of DALA, subsequently reviewed Fletcher’s proposed decision and took over responsibility for deciding the appeal. The DALA then issued a decision on Plaintiffs’ appeal, which affirmed the fourth citation and vacated the first three. Fletcher’s and Taylor’s rationales for vacation differed, however. The superior court affirmed the DALA decision. The Supreme Court affirmed, holding (1) the superior court was correct in affirming the fourth citation; (2) the DALA chief administrative magistrate has the authority to review and approve a hearing officer’s decision in a section 27C(b)(4) appeal before a final opinion issues; and (3) under these circumstances, Taylor’s actions in completing the section 27C(b)(4) hearing and administrative decision process were appropriate. View "Lighthouse Masonry, Inc. v. Div. of Admin. Law Appeals" on Justia Law

Plaintiffs here were commissioners of the Bristol County Mosquito Control Project, which operates under Mass. Gen. Laws ch. 252 and is subject to oversight by the State Reclamation and Mosquito Control Board. Plaintiffs sought a declaration that under Mass. Gen. Laws ch. 252, 14D they had the authority to hire and set compensation rates for the Project's employees and to retain counsel. Plaintiffs also sought an order of mandamus requiring the Treasurer and Receiver General to pay those employees salary increases. A superior court judge granted summary judgment for the Board and Treasurer. The Supreme Court vacated the judgment of the superior court, holding that the record was insufficient to determine whether summary judgment was appropriate in this case. Remanded. View "Comm'rs of Bristol County Mosquito Control Dist. v. State Reclamation & Mosquito Control Bd." on Justia Law

James Walsh, an electrician, became a member of the Massachusetts Teachers' Retirement System (MTRS) when he began teaching at a vocational school. Before the effective date of his retirement in 2006, Defendant applied to MTRS to increase his anticipated retirement allowance by adding to his creditable service through the buyback of three years of creditable service based on his work experience as an electrician. MTRS assessed buyback interest to commence as of 1977, the beginning of the three-year period for which Walsh sought trade service credit. Walsh appealed, claiming that buyback interest should not have begun to accrue until 1987, when he became a member of the MTRS. The Contributory Retirement Appeal Board (CRAB) reversed, holding (1) the regulation promulgated by MTRS was a valid exercise of MTRS's statutory authority; and (2) CRAB's failure to assess interest in accordance with 807 Mass. Code Regs. 14.05 was an error of law. View "Mass. Teachers' Ret. Sys. v. Contributory Ret. Appeal Bd." on Justia Law

Plaintiff filed suit against Defendants for failing to pay compensation he alleged was owed to him under an employment contract. The complaint asserted claims for, inter alia, breach of contract and violations of the Wage Act. The superior court dismissed all but Plaintiff's claim under the Wage Act, concluding that the Wage Act was the exclusive remedy for the recovery of unpaid claims, thereby preempting Plaintiff's common-law claims. The Supreme Court reversed, holding that the legislature did not intend the Wage Act to be the exclusive remedy for the recovery of unpaid wages, and therefore, Plaintiff's common-law claims should not have been dismissed. Remanded. View "Lipsitt v. Plaud" on Justia Law

The City of Boston transferred a Boston police sergeant who served as a union representative due to what the City said were ongoing concerns about the officer's supervisory authority. The Boston Police Superior Officers Federation (union) sought to enforce a provision of its collective bargaining agreement (CBA) with the City, which prohibited the involuntary transfer of certain union representatives between stations or assignments. A grievance arbitrator concluded that the City had violated the CBA and awarded the officer damages and reinstatement to his original position. The superior court confirmed the award. The Supreme Court vacated the superior court's judgment and remanded the case for judgment vacating the award, holding that the arbitrator exceeded his authority in invalidating the officer's transfer, where assignment and transfer of officers within the Boston police department are nondelegable statutory powers of the Boston police commissioner. View "City of Boston v. Boston Police Superior Officers Fed'n" on Justia Law

Employee's wife underwent surgery for removal of a brain tumor. After her tumor returned, Employer terminated Employee's employment. Employer terminated Employee because Employer was financially responsible for Employee's wife's medical condition through its health plan. Employee sued for employment discrimination, among other claims. The superior court granted Employer's motion to dismiss, finding, among other things, that Employee's claim of employment discrimination did not state a claim upon which relief could be granted, as the theory that Employer fired Employee because his wife was handicapped was not recognized in the Commonwealth. The Supreme Court reversed with respect with regard to the employment discrimination claim, holding (1) associational discrimination based on handicap is prohibited under Mass. Gen. Laws ch. 151B, 4(16); and (2) Employee alleged a plausible set of facts for relief in alleging that he was fired because of his association with his handicapped wife. View "Flagg v. Alimed, Inc." on Justia Law