Justia Massachusetts Supreme Court Opinion Summaries

This case came before the Supreme Court on Plaintiff's application for direct appellate review of a decision of the superior court affirming a decision of the contributory retirement appeal board. The case required the Court to decide whether the $200 fixed annual compensation threshold set forth in Mass. Gen. Laws ch. 32, 3(2)(d) applies to elected officials who are otherwise eligible to become members of the contributory retirement system for public employees and whether health insurance contributions and professional association dues paid on behalf of such an official are to be considered as fixed annual compensation for the purposes of this subsection. The Court affirmed the superior court, holding (1) the $200 threshold applies to "any person," including an elected official, otherwise eligible for membership under chapter 32; and (2) the value of health insurance contributions and association dues does not qualify as fixed annual compensation. View "Rotondi v. Contributory Ret. Appeal Bd." on Justia Law

Petitioners, attorneys who were the subject of disciplinary proceedings, challenged the validity of two aspects of the Commonwealth's workers' compensation, claiming (1) Mass. Gen. Laws ch. 152, 7C, which authorizes the senior judge of the department of industrial accidents to suspend the right of an attorney to "practice or appear before the department," violated the separation of powers explicitly provided for under article 30 of the Massachusetts Declaration of Rights; and (2) 452 Mass Code Regs. 1.19(3), which precludes recovery of an employee's costs and attorney's fees if the employee does not accept an insurer's offer to pay the full amount of the compensation claim, conflicted with Mass. Gen. Laws ch. 15, 13A(5), which governs the award of attorney's fees and expenses where a claim proceeds to the hearing stage. The Supreme Court reversed in part, holding (1) chapter 152, section 7C is invalid as a violation of article 30 insofar as it authorizes the senior judge of the department to suspend attorneys from appearing before the department; and (2) section 1.19(3) is a valid interpretation of chapter 152, section 13A. Remanded. View "Ellis v. Dep't of Indus. Accidents" on Justia Law

At issue in this case was (1) whether a superior court judge erred in ordering the dismissal of an age discrimination complaint filed with the Massachusetts Commission Against Discrimination for lack of subject matter jurisdiction before a final decision had been reached by the commission, and (2) whether the ministerial exception required by the First Amendment prohibits a court or administrative agency from applying Massachusetts' antidiscrimination laws to the decision of a Jewish temple not to rehire a teacher in its Sunday and after-school religious school. The Supreme Court affirmed the dismissal of the complaint, holding (1) the judge erred in deciding whether the ministerial exception barred the discrimination claim before the commission had entered a final decision on the claim; but (2) the dismissal of the complaint was proper because the ministerial exception barred the teacher's claim of discrimination. View "Temple Emanuel of Newton v. Mass. Comm'n Against Discrimination" on Justia Law

Ernest Murphy was employed by the Commonwealth as a superior court judge for eight years. Following the publication of libelous articles about Murphy's performance of his judicial duties, and his subsequent receipt of hate mail and death threats, Murphy was diagnosed with PTSD and major depressive disorder and was unable to continue performing the essential duties of his job. The state board of retirement rejected his application for accidental disability retirement benefits pursuant to Mass. Gen. Laws 32, 7, and this denial was upheld by the contributory retirement appeal board (CRAB). At issue before the Supreme Court was whether Murphy was entitled to receive accidental disability retirement benefits on the grounds that he was permanently disabled from performing the essential duties of his job by reason of a personal injury sustained as a result of, and while in the performance of, his duties. The Court affirmed, holding that Murphy did not sustain his disabling injuries while in the performance of his judicial duties, as (1) Murphy was not engaged in judicial work during the time he opened and read the death threat; and (2) the act of opening and reading his mail was, in itself, not a judicial duty. View "Murphy v. Contributory Ret. Appeal Bd." on Justia Law

Plaintiff commenced an action in the Superior Court, claiming that defendants wrongfully subjected them to a mandatory furlough plan that was ordered by the Governor. A superior Court judge allowed defendants' motion to dismiss the complaint. Plaintiffs appealed and the court transferred the case on its own motion. Because the court concluded that plaintiffs failed to offer a valid statutory basis to challenge the implementation of the furlough plan, the court affirmed the judgment. View "Massachusetts State Police Commissioned Officers Assoc. & others v. Commonwealth & others" on Justia Law

This case arose when plaintiff, a Massachusetts resident, entered into an executive employment contract with defendant. A forum selection clause dictated that all disputes arising out of the contract or the employment relationship were to be resolved in courts situated in Erie County, New York, defendant's principal place of business. The court concluded that a forum selection clause operated as a special contract only when three conditions were met: the employer's claim was covered by the Massachusetts Wage Act, G.L.c. 149, sections 148, 150; the court of the forum state, applying its choice-of-law principles, would choose a law other than that of Massachusetts to govern the dispute; and application of the foreign law would deprive the employee of a substantive right guaranteed by the Wage Act. Under modern choice-of-law doctrines, these conditions rarely coincided. On the facts alleged in the case, a New York court, applying New York's choice-of-law doctrine, would certainly apply the Wage Act to this dispute. Therefore, the court held that because enforcement of the forum selection clause would not deprive plaintiff of the protections of the Wage Act, dismissal of the action was affirmed. View "Melia v. Zenhire, Inc., & another." on Justia Law

An insurer appealed from a decision related to an employee's injury in a metal rolling machine accident. The court concluded that the board was not arbitrary or capricious in deciding that there was insufficient evidence to find that the employee was entitled under G.L.c. 152, section 51 to compensation based on an amount greater than his average weekly wage. But the court concluded that the board erred in finding that the employee's compensation should be based on the average weekly wage he earned when injured in 1980 rather than the out-of-state average weekly wage he earned when that injury recurred in 2003. The court also affirmed the board's decision to vacate the denial of recoupment for the insurer's overpayment of temporary total disability benefits between 1985 and 1988, but noted that, should the insurer decide to renew its claim for recoupment in a separate complaint filed with the department, its claim could prevail only if recoupment was equitable in the circumstances. View "Scott Wadsworth's Case" on Justia Law

In this consolidated appeal, the court construed the payment obligations of municipalities participating in G.L.c. 41, section 108L, (Quinn Bill), a local statute establishing a career incentive pay program for police officers. The underlying case arose when the Commonwealth, facing budgetary constraints, substantially cut reimbursements. Plaintiffs subsequently contended that clauses in the collective bargaining agreements (CBA) impermissibly conflict with the statute, which they viewed as requiring the city to pay 100% of benefits irrespective of reimbursement. The court held that the CBAs did not conflict with the statute and were valid. Section 108L required only that municipalities pay one-half the amounts specified in the payment provision, plus any amount actually received from the Commonwealth. Municipalities could agree to pay more, but the statute did not require it. Therefore, the cases were remanded to the county court, where the single justice was directed to issue a declaration stating that, with respect to section 108L, the CBAs between the city and the various police unions were valid and enforceable. View "Adams v. City of Boston" on Justia Law

A United States District Court judge for the District of Massachusetts ruled in this case that defendant misclassified as independent contractors those plaintiffs who were Massachusetts residents. The judge certified to this court questions related to calculation of damages for one such plaintiff. The certified questions related to whether, under Massachusetts law, an employer could use a system of customer accounts receivable financing to pay its employee at the time the customer paid the employer for the employee's work rather than when the work was performed; and whether, under the Massachusetts Wage Act, G.L.c. 149, section 148, 150, an employer and an employee could agree that the employee would pay the cost of workers' compensation and other work-related insurance coverage. The court held that the accounts receivable financing system at issue improperly deferred payment of the employee's earned wages, and that an employer could not deduct the insurance costs from an employee's earned wages. In response to the judge's invitation to provide additional guidance, the court also addressed the question whether defendant could deduct "franchise fees" from such wages, and concluded that the Wage Act forbade the deductions. View "Awuah & others v. Coverall North America, Inc." on Justia Law

This case arose when plaintiff filed a complaint against her former employer, claiming that his failure to pay her a referral fee was a breach of contract and violated the Wage Act, G.L.c. 149, sections 148, 150. At issue was whether a 2008 amendment to the enforcement section of the Wage Act, providing for a mandatory award of treble damages to a prevailing employee, should be applied in an action brought by an employee against her employer for violation of the Wage Act before the amendment's effective date. The court held that the amendment should be read to apply only prospectively, to claims arising on or after the amendment's effective date of July 12, 2008. Therefore, because the Superior Court judge applied the amendment retrospectively, the court remanded for further proceedings. View "Rosnov v. Molloy" on Justia Law