Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the decisions of the superior court judges allowing two police officers’ motions for judgment on the pleadings and vacating the decisions of the Essex Regional Retirement Board and the State Board of Retirement denying the officers a retirement allowance under Mass. Gen. Laws ch. 32, 15(4) due to the officers’ respective criminal convictions, holding that requiring the forfeiture of the officers’ pension allowances was in error.John Swallow, a police sergeant for the town of Manchester-by-the-Sea, was on administrative leave when he was charged with crimes related to the discharge of his personal firearm. Brian O’Hare, a police sergeant of the State police, was charged with the federal crime of using the Internet to entice a person under the age of eighteen to engage in unlawful sexual activity. The two boards in these cases each concluded that the officers’ convictions violated the fundamental tenets of their positions as law enforcement officials and denied them a retirement allowance. The Supreme Judicial Court reversed, holding that section 15(4) did not require the forfeiture of the officers' pension allowances. View "Essex Regional Retirement Board v. Swallow" on Justia Law

The Supreme Judicial Court affirmed the superior court’s dismissal of employees’ (Employees) putative class action lawsuit brought against the corporate officers (Officers) of a ISIS Parenting, Inc. (Company), holding that the superior court judge properly granted the Officers’ motion to dismiss.After the Company abruptly ceased operations and terminated its entire workforce, the Employees brought a class action lawsuit against the Company in federal court alleging a violation of the Federal Worker Adjustment and Retraining Notification Act, 29 U.S.C. 2101-2109 (WARN Act). After receiving a nearly $2 million default judgment, the Employees brought a putative class action lawsuit against the Officers in state court under Mass. Gen. Laws ch. 149, 148 (Wage Act), alleging (1) the WARN Act damages constituted wrongfully withheld “earned wages” for which the Officers were liable; and (2) the Officers committed a breach of fiduciary duties owed to the Company by allowing the Company to violate the WARN Act. The superior court granted the Officers’ motion to dismiss. The Supreme Judicial Court affirmed, holding that the Employees’ complaint was properly dismissed because (1) WARN Act damages are not “earned wages” under the Wage Act; and (2) the Employees did not assert a viable claim for breach of fiduciary duties. View "Calixto v. Coughlin" on Justia Law

The Supreme Judicial Court affirmed the order of the superior court judge confirming an arbitration award, holding that the award did not violate public policy under the circumstances of this case.Employee, a police officer, was terminated from his position as a police officer in the Pittsfield police department for making false statements. Thereafter, Employee’s union (Union) filed a grievance under a collective bargaining agreement between the Union and the City of Pittsfield. An arbitrator found that there was not just cause for termination and reinstated Employee. The City commenced an action pursuant to Mass. Gen. Laws ch. 150C, 11 to vacate the arbitrator’s award, arguing that it was contrary to public policy. A superior court judge confirmed the arbitration award. The Supreme Court affirmed, holding that where the arbitrator found that Employee’s statements were not intentionally false and did not lead to a wrongful arrest of prosecution or result in any deprivation of liberty or denial of civil rights, the arbitrator’s award of reinstatement did not violate public policy. View "City of Pittsfield v. Local 447 International Brotherhood of Police Officers" on Justia Law

The independent contractor statute, Mass. Gen. Laws ch. 149, 148B, does not determine whether a claimant is an employee for the purpose of workers’ compensation benefits under Mass. Gen. Laws ch. 152.Claimant sought review of a decision by the reviewing board of the Department of Industrial Accidents affirming the findings of an administrative judge concluding that the claimant was an independent contractor and therefore not entitled to workers’ compensation. The Supreme Court held (1) the reviewing board properly applied the workers’ compensation statute’s definition of employee to determine whether the claimant in this case was an employee under chapter 152; and (2) therefore, the claimant was properly classified as an independent contractor for workers’ compensation purposes. View "Camargo's Case" on Justia Law

The independent contractor statute, Mass. Gen. Laws ch. 149, 148B, does not determine whether a claimant is an employee for the purpose of workers’ compensation benefits under Mass. Gen. Laws ch. 152.Claimant sought review of a decision by the reviewing board of the Department of Industrial Accidents affirming the findings of an administrative judge concluding that the claimant was an independent contractor and therefore not entitled to workers’ compensation. The Supreme Court held (1) the reviewing board properly applied the workers’ compensation statute’s definition of employee to determine whether the claimant in this case was an employee under chapter 152; and (2) therefore, the claimant was properly classified as an independent contractor for workers’ compensation purposes. View "Camargo's Case" on Justia Law

Under the circumstances of this case, Mass. Gen. Laws ch. 30, 46D did not provide Luis Spencer, who resigned under pressure as Commissioner of Correction, a right to revert to a tenured civil service correction officer position in last held in 1992.Spencer brought a complaint against the Civil Service Commission and the Department of Correction, seeking judicial review of the Commission’s decision concluding that the right to revert to a civil service position applies only to involuntary terminations, not voluntary resignations, and because Spencer voluntarily resigned, no “termination of his service” had occurred within the meaning of section 46D. The superior court affirmed the Commission’s decision. The Supreme Judicial Court affirmed, holding (1) the Commission’s interpretation of this ambiguous statutory language was reasonable; and (2) the Commission correctly concluded that Spencer’s resignation was voluntary. View "Spencer v. Civil Service Commission" on Justia Law

Under the circumstances of this case, Mass. Gen. Laws ch. 30, 46D did not provide Luis Spencer, who resigned under pressure as Commissioner of Correction, a right to revert to a tenured civil service correction officer position in last held in 1992.Spencer brought a complaint against the Civil Service Commission and the Department of Correction, seeking judicial review of the Commission’s decision concluding that the right to revert to a civil service position applies only to involuntary terminations, not voluntary resignations, and because Spencer voluntarily resigned, no “termination of his service” had occurred within the meaning of section 46D. The superior court affirmed the Commission’s decision. The Supreme Judicial Court affirmed, holding (1) the Commission’s interpretation of this ambiguous statutory language was reasonable; and (2) the Commission correctly concluded that Spencer’s resignation was voluntary. View "Spencer v. Civil Service Commission" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court affirming a determination by the Contributory Retirement Appeal Board (CRAB) that sick or vacation payments, when used to supplement workers’ compensation payments, are not “regular compensation” as defined in Mass. Gen. Laws ch. 32, 1.On appeal, the Public Employee Retirement Administration Commission (PERAC) argued that CRAB erred in determining that the supplemental pay received pursuant to Mass. Gen. Laws ch. 152, 69 does not constitute “regular compensation” as defined in Mass. Gen. Laws ch. 32, 1 when received in conjunction with workers’ compensation. The Supreme Judicial Court disagreed, holding that CRAB’s decision was not incorrect as a matter of law. View "Public Employee Retirement Administration Commission v. Contributory Retirement Appeal Board" on Justia Law

The bus drivers in this case were not entitled to overtime payment because their employer was licensed and regulated pursuant to the common carrier statute.Plaintiff-bus drivers worked for Eastern Bus Company. Eastern Bus provided charter service, for which it must hold a license under the common carrier statute, and transportation of school students between home and school, which does not constitute charter service. The bus drivers, who performed both of these services, claimed that they were entitled to overtime payment because, among other things, the exemption to the Massachusetts overtime statute (see Mass. Gen. Laws ch. 151, 1A(11)) only applied during the hours Eastern Bus was providing charter service. The superior court concluded that Eastern Bus did not enjoy “a blanket exemption” for all employees, regardless of the particular duties they perform, that the overtime exemption did not apply, and that Plaintiffs were entitled to summary judgment on their claim for overtime wages. The Supreme Judicial Court reversed, holding that the bus drivers were not entitled to overtime payment because their employer was licensed and regulated pursuant to the common carrier statute. View "Casseus v. Eastern Bus Company, Inc." on Justia Law

Payment for accrued, unused sick time (sick pay) does not count as “wages” under the Wage Act, Mass. Gen. Laws ch. 149, sections 148, 150.The superior court allowed Plaintiff’s motion for judgment on the pleadings in this case alleging that Defendant, Plaintiff’s former employer, failed to timely compensate Plaintiff for his accrued, unused sick time under the Act. The Supreme Judicial Court vacated the judgment and remanded the matter to the superior court, holding (1) the Act does not encompass sick pay; and (2) therefore, Defendant did not violate the Act by failing to compensate Plaintiff for his accrued, unused sick time within the time frame mandated by the Act. View "Mui v. Massachusetts Port Authority" on Justia Law