Justia Massachusetts Supreme Court Opinion Summaries

Defendants were two passengers and a driver in a vehicle pulled over by a police officer for a traffic offense. The defendant passengers left the scene despite the officer's order for them to return to the automobile. The defendant driver was arrested for driving without a valid license. Subsequently two police officers searched the vehicle and found a firearm and drugs. Defendants were charged with various drug and firearm offenses. Defendants moved to suppress the evidence seized from the vehicle. The superior court allowed the motions, concluding that the warrantless search of the vehicle was not justified under any exception to the warrant requirement. The Supreme Court affirmed, holding (1) because the firearm was not in plain view, the search could not be justified as a search incident to arrest; and (2) because the defendant passengers did not abandon the contents of the vehicle when they left the scene, the search of the vehicle constituted an unlawful warrantless search. View "Commonwealth v. Perkins" on Justia Law

Defendant was a sex offender subject to the requirements of the Sex offender Registration and Community Notification Act. Following his release in prison, Defendant pleaded guilty to failing to register as a sex offender in violation of Mass. Gen. Laws ch. 6, 178H(a). The district judge imposed a fine and imposed community parole supervision for life (CPSL). Defendant moved to vacate the imposition of CPSL and to withdraw his pleas. The judge denied Defendant's motions. The Supreme Court affirmed, holding (1) chapter 6, section 178H(a) authorizes the imposition of CPSL where the sentence is a fine; (2) the amendment of the complaint to add Defendant's prior convictions serving as predicate offenses for the imposition of CPSL was proper; (3) Defendant received effective assistance of counsel in connection with the plea process; (4) the district court judge correctly found Defendant was criminally liable for failing to register; and (5) the district court judge did not abuse her discretion in denying Defendant's motion for a new trial on the basis of newly discovered evidence. View "Commonwealth v. Domino" on Justia Law

Employee filed suit against Employer, a limited liability company (LLC), and two of its managers under the Massachusetts Wage Act for failing to pay compensation that was allegedly owed to him under an employment contract. The superior court granted the managers' motion to dismiss, concluding that the Wage Act does not, by its plain language, impose individual liability on the managers of an LLC. The Supreme Court vacated the judgment of dismissal, holding that a manager who "controls, directs, and participates to a substantial degree in formulating and determining" the financial policy of the business entity may be a person having "employees in his service" under the Wage Act, and thus may be civilly or criminally liable for violations of the Act. Remanded. View "Cook v. Patient Edu, LLC" on Justia Law

After a jury trial, Defendant was convicted of involuntary manslaughter. At trial, Defendant contended that he stabbed the victim to death in self-defense. The evidence indicated that the victim was the first to provoke a nondeadly altercation with Defendant, but a dispute arose as to whether Defendant or the victim was the first to grab the knife that escalated the conflict into a deadly dispute. Defendant appealed, arguing that the trial judge erred by excluding evidence that the victim had participated in a violent assault of a third person less than two years after the incident resulting in the victim's death. The Supreme Court vacated the conviction, holding (1) a judge may admit "adjutant evidence" where there is a dispute as to who initiated a threat or use of deadly force; (2) the judge here erred in concluding that adjutant evidence was admissible only where there was a dispute as to who threatened or struck the first blow; and (3) this mistake resulted in prejudice to Defendant. Remanded for a new trial. View "Commonwealth v. Chambers" on Justia Law

After a jury trial, Defendant was convicted of posing or exhibiting a child in a state of sexual conduct. The case was tried under the "live performance" prong of Mass. Gen. Laws ch. 272, 29A(b). The Supreme Court affirmed the conviction, holding (1) the trial judge did not err in denying Defendant's motion for a required finding of not guilty because the state sufficiently proved the victim's conduct satisfied the statutory definition of a "live performance"; and (2) expert testimony was not required to aid the jury in understanding how the alleged "live performance" occurred. View "Commonwealth v. Bundy" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of felony-murder, armed burglary, and assault and battery by means of a dangerous weapon. The Supreme Court affirmed Defendant's convictions of felony-murder and assault and battery by means of a dangerous weapon and vacated Defendant's armed burglary conviction, holding (1) the trial judge did not err in instructing the jury; (2) trial counsel was not ineffective; (3) the prosecutor's closing argument did not create a substantial likelihood of a miscarriage of justice; but (4) Defendant's conviction for armed burglary was duplicative of his conviction for felony-murder. View "Commonwealth v. Alcequiecz" on Justia Law

Plaintiffs were individuals who entered into contracts with Defendants for the provision of janitorial services to third-party customers. Plaintiffs filed this putative class action, alleging that Defendants violated the Massachusetts Wage Act. Defendants moved to stay the court proceedings pending arbitration according to the terms of the arbitration clause contained in the parties' franchise agreements. The superior court denied the motion, concluding that the arbitration clause was unenforceable as set forth in Feeny v. Dell Inc. (Feeney I). After the United States Supreme Court decided AT&T Mobility LLC v. Concepcion, Defendants sought appellate review, which the Supreme Court granted. The Supreme Court reversed the order invalidating the arbitration in light of its interpretation of Conception and its impact on Feeney I, as set forth in Feeney II, holding (1) Massachusetts public policy in favor of class proceedings in certain contexts may no longer serve, in and of itself, as grounds to invalidate a class waiver in an arbitration agreement; and (2) in this case, Plaintiffs failed to demonstrate they lacked a practical means to pursue their claims on an individual basis. View "Machado v. System4 LLC" on Justia Law

Plaintiffs commenced a putative class action against Defendant, alleging violations of Mass. Gen. Laws ch. 93A. Dell successfully moved to compel arbitration according to an arbitration agreement signed by the parties. An arbitrator concluded that the parties waived class action relief by signing the agreement. In Feeney I, the Supreme Court invalidated the class waiver provision in the arbitration agreement. In this subsequent appeal, the Supreme Court held that the arbitration agreement was properly invalidated where (1) Mobility LLC v. Concepcion, decided by the U.S. Supreme Court after Feeney I, precluded the invalidation of class waiver provisions in arbitration clauses in consumer contracts, such as the one at issue here, and therefore, Concepcion undid the principal rationale for the Court's decision in Feeney I; (2) a court is not foreclosed from invalidating an arbitration agreement that includes a class action waiver where a plaintiff can demonstrate he effectively cannot pursue a claim against the defendant in individual arbitration according to the terms of his agreement, thus rendering his or her claim nonremediable; and (3) Plaintiffs demonstrated that they could not pursue their statutory claim under the individual claim arbitration process required by the arbitration agreement. View "Feeney v. Dell Inc." on Justia Law

Marie Evans died at fifty-four years old from small cell lung cancer caused by smoking cigarettes. Marie's son, Willie Evans, filed this action against Lorillard Tobacco Company (Defendant), the designer and manufacturer of Newport brand cigarettes. A jury (1) found Defendant caused Marie's wrongful death based on various theories of liability; (2) found Marie also to be negligent, and apportioned a percentage of the comparative negligence to her; (3) awarded damages to Plaintiff for the loss of Marie's companionship and awarded damages to Marie's estate for her conscious pain and suffering; and (4) awarded punitive damages. The judge also found Lorillard violated Mass. Gen. Laws ch. 93A, 2. The Supreme Court reversed in part, holding (1) the jury was not adequately instructed regarding the claim of wrongful death based on the theories of negligent design and marketing, and therefore, the jury's finding that Marie's wrongful death was caused by Lorillard's negligence and the award of punitive damages must be vacated; and (2) the judge erred in finding Lorillard committed unfair acts or practices in the conduct of trade or commerce, and therefore, Plaintiff's claim under chapter 93A must be vacated. Remanded. View "Evans v. Lorillard Tobacco Co." on Justia Law

After a jury trial, Defendant was convicted of indecent assault and battery in violation of Mass. Gen. Laws ch. 265, 13H and two counts of contributing to the delinquency of a child in violation of Mass. Gen. Laws ch. 119, 63. The Supreme Court (1) reversed the indecent assault and battery conviction, holding that the trial judge erred by limiting Defendant's ability to impeach the victim's credibility through eliciting from a police statement the victim's earlier inconsistent statements, and the error was prejudicial; and (2) reversed Defendant's conviction of contributing to the delinquency of a child that rested on Defendant's delivery of alcohol to his daughter, holding that the Legislature did not intend chapter 138, section 34 to prohibit a parent's delivery of alcohol to his minor children. View "Commonwealth v. Parent" on Justia Law