Justia Massachusetts Supreme Court Opinion Summaries

Selmark Associates, Inc. and Marathon Sales, Ltd. were closely held Massachusetts corporations that operated manufacturer’s representative companies. In 2001, Evan Ehrlich entered into a series of written agreements providing for the gradual sale of Marathon to Selmark and Ehrlich. Ehrlich subsequently became an employee and minority shareholder of Marathon. After Marathon and Selmark’s then-sole shareholder, David Elofson, terminated Ehrlich’s employment with Marathon, Ehrlich took a job with Tiger Electronics, a competing manufacturer’s representative company, where Ehrlich attempted to solicit several Marathon principals’ business. In 2008, Selmark and Marathon filed a breach of fiduciary complaint against Ehrlich. In response, Ehrlich asserted several counterclaims against Selmark, Marathon, and Elofson. The fury found (1) Ehrlich breached his fiduciary duties to Marathon by soliciting and acquiring Marathon principals for Tiger; (2) Selmark and Elofson committed a breach of contract to Ehrlich and breached their fiduciary duties to Ehrlich; and (3) all the Selmark parties engaged in unfair or deceptive acts or practices. The Supreme Judicial Court (1) affirmed the jury verdict in favor of Selmark and Marathon on their breach of fiduciary duty claim against Ehrlich; (2) affirmed the verdict in favor of Ehrlich on his breach of fiduciary duty counterclaim against Selmark and Elofson; (3) concluded that Ehrlich was entitled to recover on his breach of contract counterclaim but vacated the award of damages and remanded for a new trial on the issue of contractual damages; and (4) concluded that Ehrlich was not entitled to recover under Mass. Gen. Laws ch. 93A. View "Selmark Assocs., Inc. v. Ehrlich" on Justia Law

Stephanie Moulton was employed as a residential treatment counselor at North Suffolk Mental Health Association, Inc. when she was assaulted by DeShawn Chappell, one of the facility’s residents, causing her death. Moulton’s estate brought an action against the directors of North Suffolk, among other defendants, asserting claims for wrongful death and breach of fiduciary duty. The director defendants moved to dismiss the complaint on the grounds that (1) with respect to the wrongful death action, they were immune from suit, as Moulton’s employer, under the exclusive remedy provision of the Workers’ Compensation Act (Act); and (2) with respect to the breach of fiduciary duty claim, they owed Moulton no such duty. The superior court denied the director defendants’ motion to dismiss. The Supreme Judicial Court vacated the superior court’s judgment, holding (1) the director defendants were immune from suit under the exclusive remedy provision of the Act for the injuries Moulton sustained while acting within the course of her employment; and (2) the directors, as Moulton’s employer, owed no fiduciary duty to their employee. Remanded for an entry of judgment for the director defendants on all claims. View "Estate of Moulton v. Puopolo" on Justia Law

After a jury trial, Defendant was convicted of first degree murder on a theory of felony-murder and aggravated rape. The conviction of murder was affirmed on appeal and the conviction of aggravated rape was vacated as duplicative. Since 2002, Defendant unsuccessfully sought to obtain DNA testing of the physical evidence that was used to support the expert opinion evidence introduced at trial. In 2012, Defendant filed a motion for DNA testing pursuant to Mass. Gen. Laws ch. 278A, 3, asserting that he was factually innocent of the crimes for which he was convicted and that DNA testing could establish the identity of a third party who contributed to seminal fluid found in the victim’s vagina and clothes and “may wholly exonerate” him. The motion judge denied Defendant’s motion. The Supreme Court reversed, holding that the motion judge applied an incorrect standard in denying Defendant’s motion for DNA testing and that the motion met the requirements of Mass. Gen. Laws ch. 278A, 3. Remanded. View "Commonwealth v. Wade" on Justia Law

After a probation revocation hearing, a district court judge found that Defendant had violated the conditions of his probation and revoked Defendant's probation. On appeal, Defendant argued, among other things, that the judge made no separate finding as to good cause for proceeding without a witness with personal knowledge of the evidence presented, as required by Rule 6(b) of the District Court Rules for Probation Violation Proceedings. The Supreme Court affirmed, holding (1) the hearing comported with due process because the hearsay testimony on which the judge relied was substantially reliable and trustworthy; (2) Rule 6(b) of the District Court Rules of Probation Violation Proceedings is not to be construed as requiring more than is constitutionally mandated, and due process does not require, when the hearsay is substantially reliable, separate proof as to good cause; and (3) there was no improper interference by the office of the district attorney with the probation department’s conduct of the hearing that would give rise to a violation of article 30 of the Massachusetts Declaration of Rights. View "Commonwealth v. Bukin" on Justia Law

Defendant, his brother, his sister-in-law, and his cousin worked together in a tiling business in Oklahoma. All four individuals were hired to install tile in a fast-food restaurant under construction in Clinton. While working on the job, Defendant stabbed and killed the general manager with no apparent provocation or motive. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress statements Defendant made to the police; (2) the joinder of the firearms charges with the murder charge for trial did not prejudice Defendant; (3) the admission of certain hearsay evidence at trial did not prejudice Defendant; (4) the trial court did not err in denying Defendant’s first motion for a new trial without an evidentiary hearing; and (5) trial counsel was not ineffective for failing to pursue a defense of lack of criminal responsibility based on evidence that Defendant may have been suffering from a spontaneous recurrence of methamphetamine-induced psychosis at the time of the stabbing. View "Commonwealth v. Spray" on Justia Law

On April 12, 2010, U.S. Bank National Association initiated a summary process action against Defendant, seeking to evict him from property he owned following the property’s sale to the Bank at a foreclosure auction. On May 25, 2012, a judge entered judgment in favor of the Bank for possession. Defendant appealed, arguing that the foreclosure sale was void because the notice of his right to cure a default did not satisfy the provisions of Mass. Gen. Laws ch. 244, 35A, which gives a mortgagor of residential real property a ninety-day right to cure a payment of default before foreclosure proceedings may be commenced. The Supreme Judicial Court affirmed, holding (1) section 35A is not one of the statutes relating to the foreclosure of mortgages by the exercise of a power of sale, and (2) that being the case, and given the deficiencies in the steps Defendant took to obtain relief, Defendant was precluded from challenging the Bank’s compliance with section 35A in this summary process action. View "U.S. Bank Nat'l Ass'n v. Schumacher" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation and of unlawful possession of a firearm. The Supreme Judicial Court affirmed the order denying Defendant’s motion to suppress identification evidence and affirmed Defendant’s convictions, holding that the trial judge did not err in (1) denying Defendant’s motion to suppress, as the police had good reason to conduct a showup identification procedure, and Defendant did not meet his burden of showing that he was subjected to a showup identification procedure that was unnecessarily suggestive; (2) admitting into evidence surveillance videotape recordings; (3) limiting cross-examination of a witness on the issue of bias; (4) deciding not to discharge a juror; and (5) instructing the jury. View "Commonwealth v. Meas" on Justia Law

Plaintiff filed an application for an ex parte temporary restraining order under Mass. Gen. Laws ch. 209A, 4 against Defendant. A probate and family court judge issued a permanent abuse prevention order directing Defendant to refrain from abusing or contacting Plaintiff, to stay away from her residence, and to surrender any firearms or ammunition to the police department. Defendant did not challenge the permanent order on direct appeal. Twelve years later, Defendant later moved to terminate the permanent abuse prevention order. A judge denied Defendant’s motion. The Supreme Judicial Court affirmed, holding (1) a Defendant who seeks to terminate a permanent abuse prevention order must show, by clear and convincing evidence, that, as a result of a significant change in circumstances, it is no longer equitable for the order to continue because the protected party no longer has a reasonable fear of imminent serious physical harm; and (2) in light of the totality of the circumstances in this case, the judge did not abuse her discretion in denying Defendant’s motion. View "MacDonald v. Caruso" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder in the first degree. The Supreme Judicial Court affirmed the convictions, holding that the trial judge (1) did not err in denying Defendant’s motion to suppress his statements to police; (2) did not deny Defendant’s Sixth Amendment right to a fair trial by denying Defendant’s motion for a change of venue; (3) did not err in denying the admission of certain “third-party culprit” evidence and Defendant’s request for a third-party culprit instruction at trial; and (4) did not abuse his discretion in excluding expert testimony regarding the phenomenon of false confessions. View "Commonwealth v. Hoose" on Justia Law

Defendant admitted to sufficient facts to warrant a finding of guilty for possessing a class B controlled substance. The substance was tested at the forensic drug lab at the William A. Hinton State Laboratory Institute. The lab issued a drug certificate identifying the substance as one containing cocaine, and the first signature on the drug certificate was Annie Dookhan’s. Dookhan, a chemist at the drug lab, was indicted on multiple counts of evidence tampering and obstruction of justice, among other charges, relating to her handling and testing of samples at the lab. Defendant moved to vacate his underlying guilty plea on the basis of Dookhan’s involvement in testing the substance found in Defendant’s possession. The motion judge granted Defendant’s motion to vacate his guilty plea. The Supreme Court vacated the order, holding (1) where Dookhan signed the certificate of drug analysis as either the primary or secondary chemist in Defendant’s case, Defendant was entitled to a conclusive presumption that Dookhan’s misconduct occurred in his case; and (2) in order to prevail on his motion, Defendant must demonstrate a reasonable probability that knowledge of Dookhan’s misconduct would have materially influenced his decision to tender a guilty plea. Remanded. View "Commonwealth v. Scott" on Justia Law