Justia Massachusetts Supreme Court Opinion Summaries

Plaintiffs were individuals who lived in New York and worked there as couriers for Defendant, a corporation headquartered in Massachusetts. Plaintiffs brought this action in a Massachusetts court to enforce certain Massachusetts independent contractor, wage, and overtime pay statutes. The superior court dismissed the complaint, concluding (1) the Massachusetts independent contractor statute does not apply to non-Massachusetts residents working outside Massachusetts, and (2) as independent contractors, Plaintiffs failed to state claims under the Massachusetts wage statutes. The Supreme Court vacated the judgment of dismissal and remanded for further proceedings, holding that, insofar as the written contract between the parties contained an enforceable clause requiring both that actions be brought in Massachusetts and requiring that the contract and all rights and obligations of the parties be determined under Massachusetts law, and where application of Massachusetts law is not contrary to a fundamental policy of the jurisdiction where the individuals live and work, it was error to dismiss Plaintiffs' complaint. View "Taylor v. E. Connection Operating, Inc." on Justia Law

Defendant pleaded guilty to possession of child pornography, requiring him to register as a sex offender. Defendant was placed on probation by a superior court judge. Upon Defendant's motion seeking relief from the requirement that he register as a sex offender, the sentencing judge concluded that Defendant had demonstrated that he did not pose a risk of reoffense or a danger to the public and relieved him of the registration requirement. Almost three years later, a second superior court judge found Defendant in violation of his probation and, on that basis, ordered Defendant to register with the Sex Offender Registry Board. The Supreme Court reversed, holding that, under the terms of the Sex Offender Registry Act, the second judge was without authority to require registration as a sex offender as a condition of probation or to revoke the prior grant of relief from registration. View "Commonwealth v. Ventura" on Justia Law

After a jury trial, Defendant was convicted of indecent assault and battery on a child under the age of fourteen years and rape of a child under the age of sixteen years. Defendant unsuccessfully moved for a judgment notwithstanding the verdict, arguing that his conduct underlying the conviction of indecent assault and battery was not separate and distinct from his conduct constituting statutory rape because the moving of the victim's clothing was necessary to the rape. The Supreme Court vacated Defendant's conviction of indecent assault and battery on a child under fourteen and affirmed his conviction of rape of a child under sixteen, holding that Defendant's actions underlying the two convictions were not separate and distinct. View "Commonwealth v. Suero" on Justia Law

After falling down a staircase at a bar and restaurant in Boston, a college student died. Plaintiffs, the student's parents, filed this action against the restaurant and trustees of a trust that owned the land and buildings within which the restaurant operated. The complaint alleged claims against the restaurant and trustees for wrongful death and for violation of Mass. Gen. Laws ch. 93A. Plaintiffs based their chapter 93A claim on Defendants' alleged building code violations, which Plaintiffs claimed constituted unfair or deceptive conduct. A jury returned a verdict for Defendants on Plaintiffs' wrongful death claims, and the trial judge found in favor of Plaintiffs on the chapter 93A claim, finding that the student fell and suffered a fatal injury because the stairs were in an unsafe, defective condition having been rebuilt without necessary building permits. The Supreme Court vacated the judgment, holding that Plaintiffs were entitled to recover on their chapter 93A claim but that the judge erred in her calculation and award of damages. Remanded. View "Klairmont v. Gainsboro Rest., Inc." on Justia Law

Plaintiff was injured when he unsuccessfully tried to flip into an inflatable pool from a trampoline that had been set up directly adjacent to the pool in the backyard of a property he was renting from Defendants. Plaintiff filed a claim for negligence against Defendants for setting up and maintaining the trampoline next to the pool and for failing to warn him of the danger of jumping from the trampoline into the pool. The trial court ruled in favor of Defendants. The appeals court affirmed. The Supreme Court reversed, holding (1) a landowner has a duty to remedy an open and obvious danger where he has created and maintained that danger with the knowledge that lawful entrants would choose to encounter it despite the obvious risk of doing so; and (2) the judge erred in instructing the jury to cease deliberations if they concluded that the danger was open and obvious, and should have further instructed the jury that a landowner is not relieved from remedying open and obvious dangers where he can or should anticipate that the dangerous condition will cause physical harm to the lawful entrant notwithstanding its known or obvious danger. View "Dos Santos v. Coleta" on Justia Law

Defendant pleaded guilty to rape of a child and indecent assault and battery. When Defendant, who was homeless, failed to appear at the local police department to verify his registration information, the Commonwealth charged him by complaint with failing to verify his registration information. Defendant pleaded guilty to the charge. The trial judge sentenced Defendant to thirty days committed with no community parole supervision for life (CPSL). The Commonwealth subsequently filed a petition asking the county court to compel the judge to sentence Defendant to CPSL as mandated by Mass. Gen. Laws ch. 6, 178H. A single justice of the Supreme Court allowed the petition and remanded to the trial court for further proceedings. On appeal, the Commonwealth agreed that the case was insufficient to support the imposition of CPSL but argued that by pleading guilty, Defendant waived his right to raise any argument about the sufficiency of the complaint on that point. The Supreme Court reversed the judgment of the single justice, holding that Defendant did not waive his argument concerning the insufficiency of the complaint on the CPSL issue by pleading guilty. View "Commonwealth v. Batista" on Justia Law

Defendants owned two-family and three-family rental properties in the City of Worcester. Defendants leased dwelling units in these properties to groups of four unrelated adult college students. The City determined that, where such a dwelling unit is occupied by four or more unrelated adults not within the second degree of kindred to each other, the dwelling unit is a "lodging" for purposes of the Lodging House Act, and Defendants were therefore operating a lodging house without a license. The trial court found Defendants in contempt and imposed monetary fines. The appeals court affirmed. The Supreme Court reversed, holding that the dwelling units did not meet the definition of "lodgings" under the Act, and accordingly, the properties were not lodging houses under the Act. View "City of Worcester v. College Hill Props., LLC" on Justia Law

After a jury trial, Defendant was convicted of assault with intent to murder and several firearms offenses. The appeals court affirmed. Defendant appealed, asserting, among other things, that the prosecutor misstated evidence and unjustifiably demeaned the defense, Defendant, and defense counsel in his closing argument, thereby depriving Defendant of a fair trial. The Supreme Court reversed the convictions, holding (1) the prosecutor's repeated use of the term "street thug," his reference to the "entire defense" as a "sham," and his accusation that defense counsel assisted in the presentation of lies constituted excessive argument, and therefore, these aspects of the prosecutor's closing argument were improper; and (2) Defendant was prejudiced by the improprieties in the prosecutor's closing argument. Remanded for a new trial. View "Commonwealth v. Lewis" on Justia Law

In 2001, Robert Riskind suffered a grand mal seizure while driving home from work, causing him to strike Plaintiff. Plaintiff sustained serious injuries as a result of the accident. Riskind's seizure was triggered by an inoperable brain tumor, a condition for which he had been receiving treatment from Dr. Fred Hochberg since its diagnosis. Riskind died in 2002 as a result of the brain tumor. Plaintiff subsequently filed a negligence action against Hochberg. Hochberg moved for summary judgment, arguing that, as a matter of law, he owed Plaintiff neither a duty to control Riskind nor a duty to warn Riskind against driving. A superior court judge granted Hochberg's summary judgment motion. The Supreme Court affirmed, holding (1) a medical professional, other than a mental health professional, owes no duty to a third person arising from any claimed special relationship between the medical professional and a patient; and (2) Hochberg did not owe a duty of care to Plaintiff under ordinary negligence principals. View "Medina v. Hochberg" on Justia Law

Defendant was convicted of operating while under the influence of alcohol, fifth or subsequent offense, and possession of a class D substance greater than one ounce. Defendant appealed, arguing that the superior court erred in denying his pretrial motion to suppress evidence obtained as a result of a vehicle stop conducted by a Merrimac police officer in the neighboring city of Amesbury. At issue was whether the police officer acted unlawfully by carrying his authority outside his municipal boundaries. The Supreme Court affirmed the order denying Defendant's motion to suppress, holding that the stop was authorized under the terms of the mutual aid agreement between the municipalities, and that agreement complied with the requirements of Mass. Gen. Laws ch. 40, 8G. View "Commonwealth v. Bartlett " on Justia Law