Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of possession with intent to distribute a class B controlled substance in connection with the death of Richard Beaulier. During trial, a toxicologist testifying as an expert witness for the Commonwealth testified about the results of laboratory testing and toxicological analysis of Beaulier's blood, which showed the presence of a high level of fentanyl. The toxicologist, however, had not conducted any of the testing. The appeals court affirmed the conviction, holding that the admission of the toxicology results testing conducted by a nontestifying analyst constituted constitutional error, but the error was harmless beyond a reasonable doubt. The Supreme Court affirmed, holding that the improperly admitted evidence would have had little or no effect on the fact finder, and therefore the error was harmless beyond a reasonable doubt. View "Commonwealth v. Lezynski" on Justia Law

In Feeney II, the Massachusetts Supreme Court affirmed the ruling of the superior court invalidating a class action waiver in the parties' arbitration agreement, holding that the Federal Arbitration Act (FAA) does not foreclose a court from invalidating an arbitration agreement that includes a class action waiver if it effectively denies the plaintiffs a remedy. The U.S. Supreme Court subsequently issued an opinion in American Express Co. v. Italian Colors Restaurant (Amex) holding that a class action waiver in an arbitration agreement is enforceable under the FAA even if a plaintiff proves that the class waiver effectively precludes the plaintiff from vindicating his federal statutory rights. The Massachusetts Supreme Court subsequently concluded that following Amex, the Court's analysis in Feeney II no longer comported with the U.S. Supreme Court's interpretation of the FAA, holding instead that a class waiver may not be invalidated on the grounds that it effectively denies the plaintiffs a remedy. Remanded. View "Feeney v. Dell Inc. " on Justia Law

In 1982, Plaintiff established the 1982 Trust, and four separate subtrusts therein, for the four sons of the Krafts. In 2012, Plaintiff, who had served as the sole and disinterested trustee of the trust and subtrusts, proposed to transfer all of the property of the subtrusts into new subtrusts established in accordance with the terms of a new master trust for the benefit of the Kraft sons. Plaintiff asked the Supreme Court to interpret the 1982 Trust to determine whether it authorized distributions to the new trust without the consent or approval of any beneficiary or court. The Supreme Court concluded that it did, holding that the terms of the 1982 Trust authorized Plaintiff to distribute the trust property in further trust for the benefit of the beneficiaries of the 1982 Trust without their consent or court approval. View "Morse v. Kraft" on Justia Law

A police officer obtained a search warrant to search for Defendant in someone else's residence. When the police executed the warrant, they arrested Defendant and also discovered drugs inside the residence. After a jury trial, Defendant was convicted of trafficking in cocaine and possession with intent to distribute marijuana. Defendant appealed, arguing that the search warrant was invalid because the affidavit submitted in support of that search warrant application was based on information the police obtained by trespassing into the curtilage of the residence, in violation of Defendant's Fourth Amendment rights. The Supreme Court affirmed, holding (1) a person who is the subject of a valid arrest warrant and is arrested while in a third party's residence has a right to insist the police have a reasonable belief at the time they enter the residence that the person would be present; but (2) where, as in this case, the person has disclaimed any connection to the third party's residence, he does not have a constitutional right to challenge the basis on which the search warrant issued. View "Commonwealth v. Tatum" on Justia Law

The three cases before the Supreme Court here involved the validity of certain procedures adopted by the superior court to handle postconviction matters in criminal cases where a defendant was convicted of a drug offense. The drugs at issue were analyzed at the William A. Hinton State Laboratory Institute, where chemist Annie Dookhan worked on at least 34,000 cases. At the time of this opinion, Dookhan was the subject of allegations that she falsified drug testing results, tampered with evidence, and forged signatures on documents. Here special magistrates conducted hundreds of hearings, a substantial number of which pertained to Defendants' motions to stay the execution of their sentences. The Commonwealth filed petitions challenging the superior court's procedures in handling the postconviction matters. The Supreme Court answered questions reported by a single justice by holding, among other things, that in exceptional circumstances, a judge of the superior court has the authority to allow a defendant's motion to stay the execution of his sentence, then being served, pending disposition of the defendant's motion for a new trial, but a special magistrate appointed by the chief justice of the superior court does not have such authority. View "Commonwealth v. Charles" 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

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. The Supreme Court affirmed, holding (1) the trial judge did not err in finding Defendant failed to make a prima facie case of bias regarding the prosecutor's exercise of a peremptory challenge of the only African-American male who remained in the venire; (2) the trial judge's sanctions and jury instructions crafted in response to defense counsel's violation of a reciprocal discovery order did not deny Defendant his right to a fair trial; (3) the trial judge did not err in failing to provide the jury with a Commonwealth v. DeGiambattista instruction, as Defendant was not entitled to such an instruction; and (4) the prosecutor's statements during her closing argument were not prejudicial. View "Commonwealth v. Issa" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation for the stabbing death of his wife. The Supreme Court affirmed Defendant's conviction, holding (1) portions of testimony by a substitute medical examiner violated Defendant's state and federal rights to confrontation and should not have been admitted, but the admission of the testimony did not create a substantial likelihood of a miscarriage of justice; (2) the trial judge did not abuse his discretion in denying Defendant's motion for individual voir dire of the venire with respect to each member's experience with domestic violence; and (3) the trial judge did not abuse his discretion in denying Defendant's motion to reduce the verdict to murder in the second degree. View "Commonwealth v. Reavis" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. The Supreme Court affirmed the convictions, holding (1) the superior court judge did not err in admitting testimony that the victim threatened to throw rocks at or otherwise destroy what he believed to be Defendant's house; (2) trial counsel's failure to request that the jury be specifically instructed on issues relating to eyewitness identification was not likely to have influenced the jury's conclusion, and therefore, did not result in a substantial likelihood of a miscarriage of justice; (3) the prosecutor made one improper statement in his closing argument that created no substantial likelihood of a miscarriage of justice; and (4) because the weight of the evidence supported the jury's verdict of murder in the first degree, the Court declined to exercise its extraordinary authority to grant relief under Mass. Gen. Laws. ch. 278, 33E. View "Commonwealth v. Franklin" on Justia Law

After Defendants were charged with Medicaid fraud, the Commonwealth obtained search warrants to obtain and search designated e-mail accounts of Defendants' former billing director. Defendants moved for a protective order, claiming that the attorney-client privilege protected many of the e-mails. A motion judge amended the order to permit the Commonwealth to search the e-mails by using a "taint team," assistant attorneys general not involved in the investigation or prosecution of Defendants. Defendants filed a petition seeking relief from the order. The Supreme Court answered reported questions from the county court by holding (1) the Commonwealth may, by means of an ex parte search warrant, search the post-indictment emails of a criminal defendant; and (2) the "taint team" procedure was permissible under the Massachusetts Constitution. View "Preventive Med. Assocs. v. Commonwealth" on Justia Law