Justia Massachusetts Supreme Court Opinion Summaries

The dispute involves the town of Nahant and Northeastern University over a peninsula known as East Point. Northeastern owns most of the land, using part for its Marine Science Center, while the town owns a smaller parcel at the tip, which it maintains as a public park. The town also holds an easement over Northeastern’s property for access to the park. In 2018, Northeastern announced plans to expand its campus with a new building, sparking local opposition. In response, Nahant residents voted in 2021 to authorize the town’s board of selectmen to use eminent domain to acquire conservation and access easements across portions of Northeastern’s property. The town then petitioned the Massachusetts Superior Court to establish its right to take these property interests.Northeastern challenged the taking, arguing it was undertaken in bad faith, claiming the town’s real motive was to block its development project. On cross motions for summary judgment, the Superior Court judge sided with Northeastern, finding that the town’s stated public purpose was pretextual and that its true intent was to prevent the proposed expansion. As a result, the judge dismissed the town’s petition and awarded Northeastern over $1 million in fees and costs.The Supreme Judicial Court of Massachusetts reviewed the case on direct appellate review. It held that Nahant’s stated purposes for the taking—conservation, open space, and public access—constitute valid public purposes under Massachusetts law. The Court found no reasonable expectation that Northeastern could prove the town acted in bad faith or that the taking was improperly motivated by private interests, and rejected alternative public policy arguments. The Court reversed the Superior Court’s judgment, vacated the fee award, and remanded for entry of an order establishing the town’s right to take the property interests, and for further proceedings. View "Town of Nahant v. Northeastern University" on Justia Law

A nonprofit organization and several individuals, most residing near Franklin Park in Boston, challenged the city’s decision to enter into agreements allowing a private company to demolish and reconstruct White Stadium and to lease a portion of the new stadium for use as a professional women’s soccer venue. The plaintiffs argued that the land in question, originally acquired as parkland, remained subject to Article 97 of the Amendments to the Massachusetts Constitution, which requires a two-thirds legislative vote to dispose of or change the use of protected parkland. They also claimed that the agreements breached the terms of a public charitable trust, the George Robert White Fund, from which the stadium parcel was transferred, and that the city failed to meet other statutory requirements.The Superior Court dismissed the plaintiffs’ trust-based claims for lack of standing, finding that only the Attorney General or trustees can enforce a public charitable trust unless an individual plaintiff can show a distinct personal interest. After a bench trial, the court ruled in favor of the defendants on the remaining claims, concluding that the stadium parcel was no longer protected parkland at the time of the agreements and that the plaintiffs had not demonstrated violations regarding areas outside the stadium parcel.On appeal, the Supreme Judicial Court of Massachusetts affirmed. The court held that the plaintiffs lacked standing to enforce the White Fund’s trust terms. It further determined that, due to legislative actions in 1947 and 1950, the stadium parcel was removed from its park designation and dedicated as a school facility, so Article 97’s protections did not apply. The court also found that the agreements did not grant an easement over other areas of Franklin Park and that planned improvements outside the stadium parcel did not alter their park use. The judgment for the defendants was affirmed. View "Emerald Necklace Conservancy, Inc. v. City of Boston" on Justia Law

In October 2021, while working on a roofing project at a resort in Hancock, the plaintiff, an employee of a subcontractor, fell from the roof and sustained severe injuries. The plaintiff’s employer, MBT Construction Corp., had been subcontracted by the defendant, a general contractor, to carry out the roof replacement. The subcontract did not specify which party was responsible for jobsite safety, provision of safety equipment, or worker training. On the day of the incident, the plaintiff detached his safety harness to move shingles and fell before reattaching to another safety line. MBT had previously received citations from OSHA for safety violations, but both MBT and the defendant had a longstanding business relationship.The plaintiff filed a negligence and negligent hiring suit against the defendant in the Superior Court, arguing that the defendant failed to supervise and enforce safety protocols and had hired MBT despite knowledge of its inadequate safety history. The defendant moved for summary judgment, asserting it did not owe a duty of care to the plaintiff and that state law did not recognize a negligent hiring claim in these circumstances. The Superior Court judge agreed, finding that the defendant lacked control over MBT’s work and that the plaintiff, as the subcontractor’s employee, could not bring a negligent hiring claim against the general contractor.The Supreme Judicial Court of Massachusetts reviewed the case upon transfer. It affirmed summary judgment for the defendant, holding that the general contractor did not owe a duty of care to the plaintiff because it did not retain or exercise control over the injury-producing safety measures. The Court also held that Massachusetts law does not recognize an independent negligent hiring duty owed by a general contractor to a subcontractor’s employee for injuries arising from the subcontractor’s work under these facts. The judgment for the defendant was affirmed. View "Suquilanda v. Skyway Roofing, Inc." on Justia Law

Sunpin Energy Services, LLC and Ralph P. Lapinkas, Jr. sought to construct a large-scale ground-mounted solar energy system on a parcel of undeveloped, mostly forested land in Petersham, Massachusetts. Because the proposed site was outside the town’s designated solar electric overlay district, Sunpin applied for a special permit from the Zoning Board of Appeals. The project would require clearing trees from approximately 14.3 acres, and Sunpin secured an order of conditions from the town conservation commission under the Wetlands Protection Act. The permit application was denied after one of three board members voted against it, citing concerns about deforestation and referencing the town’s bylaw goals of maintaining the town’s beauty and proper land use.The plaintiffs challenged the board’s denial in the Land Court Department. The Land Court judge granted summary judgment in favor of the board, concluding that the board member properly applied the zoning bylaw criteria, including the protection of public health, safety, and welfare, and concerns about tree removal. The plaintiffs appealed, and the Massachusetts Appeals Court vacated the judgment, holding that the board’s decision was arbitrary and capricious, improperly favoring forest preservation over solar energy siting and relying on speculation about future development.The Supreme Judicial Court of Massachusetts reviewed the case and held that, under the Dover Amendment’s solar provision (G. L. c. 40A, § 3, ninth paragraph), municipalities must provide reasonable opportunities for solar energy systems and may not deny a special permit unless it is necessary to protect public health, safety, or welfare. The Court found that the denial, based on general concerns about tree cutting, amounted to a blanket prohibition in a town that is ninety-seven percent forested, which was improper. The Court vacated the Land Court’s judgment and remanded for further proceedings consistent with its opinion. View "Sunpin Energy Services, LLC v. Zoning Board of Appeals of Petersham" on Justia Law

A general contractor and a subcontractor entered into agreements for the construction and renovation of a facility. The subcontracts required disputes to be resolved by arbitration pursuant to the rules of the American Arbitration Association. The subcontractor performed work and submitted invoices, but the general contractor, while timely rejecting the invoices and providing reasons, failed to include the good faith certification required by the Massachusetts prompt pay act. The contractor later paid the invoices after an arbitrator determined that the invoices were deemed approved due to the lack of timely certification. Subsequently, the contractor filed a counterclaim in arbitration seeking recoupment of those payments, arguing the invoices were not fair and reasonable.The subcontractor initially brought suit in the Massachusetts Superior Court, which was then compelled to arbitration per the contract. During arbitration, the arbitrator found that the contractor’s failure to timely certify its rejection of the invoices resulted in the invoices being deemed approved and ordered payment to the subcontractor. After payment, the arbitrator allowed the contractor’s counterclaim for recoupment. Following evidentiary proceedings, the arbitrator ruled in favor of the contractor, awarding partial recoupment. The subcontractor moved in the Superior Court to vacate this award, arguing that the arbitrator exceeded his authority. Relying on J.C. Cannistraro, LLC v. Columbia Construction Co., the Superior Court judge vacated the recoupment portion of the arbitration award, finding that the contractor had asserted defenses before paying the invoices, contrary to precedent.The Supreme Judicial Court of Massachusetts reviewed the matter on direct appellate review. It held that the arbitrator did not exceed his authority because the award was not prohibited by law nor did it violate public policy. The court determined that the prompt pay act did not expressly prohibit recoupment in these circumstances and that the arbitrator’s actions were within the broad scope granted by the parties’ agreement and the arbitration rules. The judgment vacating the arbitration award was reversed and the matter remanded for confirmation of the arbitration award. View "J.C. Cannistraro, LLC v. Columbia Construction Co." on Justia Law

A group of registered voters in Massachusetts challenged the Attorney General’s certification of an initiative petition proposing to limit annual rent increases for residential properties. The petition would repeal the Statewide ban on rent control and instead institute a cap on rent increases, but it expressly exempted certain types of properties, including those in facilities operated solely for religious, educational, or nonprofit purposes. The Attorney General had certified that the petition did not contain excluded matters, issued the required summary, and the Secretary of the Commonwealth prepared the petition for circulation and potential inclusion on the November 2026 ballot after sufficient signatures.The plaintiffs filed a civil action in the Supreme Judicial Court for Suffolk County, seeking a declaration that the petition was invalid under the Massachusetts Constitution, an order quashing the certification, and an injunction preventing the petition from appearing on the ballot. The parties agreed to reserve and report the case to the full Supreme Judicial Court. The central argument was that the petition impermissibly “relates to religion, religious practices or religious institutions,” which is prohibited by Article 48 of the Amendments to the Massachusetts Constitution.The Supreme Judicial Court of Massachusetts reviewed the case de novo and concluded that, because the petition included an exemption for facilities operated solely for religious purposes, it “relates to religion” within the meaning of Article 48. The Court explained that the exemption makes religion a factor in the law’s application and would require governmental determinations about religious purpose, thereby conferring preferential treatment on religious institutions. The Court held that the petition is barred from the initiative process by Article 48 and directed that it may not be placed on the 2026 Statewide election ballot. The judgment was remanded for entry of a declaratory judgment and an injunction consistent with this holding. View "Cella v. Attorney General" on Justia Law

A buyer entered into a contract to purchase a cranberry bog property that was assessed and taxed as agricultural land under Massachusetts General Laws chapter 61A. The contract acknowledged that the sale was contingent on the town’s waiver of its statutory right of first refusal. The buyer informed the seller that it intended to subdivide two lots for non-agricultural use and keep the rest agricultural. This intended use was incorporated into the notice of intent to sell, which was sent to the town as required. Later, the buyer changed its position and stated it intended to maintain the property for agricultural use, and together with the seller, attempted to withdraw the notice of intent. However, the town declined the withdrawal and exercised its option to purchase the property through its affordable housing trust.The Superior Court reviewed cross motions for summary judgment. The judge found that the notice of intent sufficiently triggered the town’s right of first refusal and that the town’s right ripened into an irrevocable option, precluding withdrawal of the notice. Judgment was entered against the buyer, who then appealed. The Supreme Judicial Court transferred the case from the Appeals Court for review.The Supreme Judicial Court held that the notice of intent to sell, which stated an intention to subdivide two lots for non-agricultural use, was sufficient under chapter 61A to trigger the town’s right of first refusal. The Court ruled that the town’s option to purchase vested upon receipt of the notice and could not be withdrawn by the seller and buyer. Additionally, the town’s option applied to the entire parcel as described in the purchase and sale agreement, not just the subdivided lots. The Court affirmed the Superior Court’s summary judgment in favor of the defendants. View "Watermark LLC v. R H Benea Cranberry Co., Inc." on Justia Law

The case concerns the sale of a manufactured housing community in Bourne, Massachusetts, owned by the Charles W. Austin Trust. The trust entered into a purchase and sale agreement with Crown Communities, LLC for $3.8 million, subject to the statutory right of first refusal afforded to resident tenants under the Manufactured Housing Act, G. L. c. 140, § 32R. After receiving notice of the pending sale, a group of residents formed an association and submitted a signed petition indicating support from more than fifty-one percent of resident tenants to exercise the right of first refusal and purchase the property. Despite gathering sufficient signatures, the association failed to secure a binding financing commitment within ninety days of executing its purchase and sale agreement with the trust.A civil action commenced in the Massachusetts Superior Court, with Crown asserting claims for declaratory relief regarding its rights to purchase the property. The association counterclaimed, seeking declaratory relief and alleging unfair practices and tortious interference by Crown. After a jury-waived trial, the Superior Court judge found that the association did not validly exercise its right of first refusal, relying on the number of signed membership agreements rather than petition signatures, and concluded that the trust must sell to Crown. The Appeals Court vacated the judgment, finding error in the Superior Court’s methodology and holding that the signed petition constituted reasonable evidence of support. The Appeals Court also ruled that Crown was estopped from challenging the association’s failure to meet the financing deadline due to its filing of a lis pendens.The Supreme Judicial Court of Massachusetts reviewed the case on direct appellate review. The Court held that a petition signed by resident tenants is “reasonable evidence” under § 32R, but found that the association’s failure to obtain financing within the statutory ninety-day period terminated its right of first refusal. The Court reversed the amended judgment that had required the trust to sell to the association and affirmed the rulings in favor of Crown on the association’s counterclaims. View "Crown Communities, LLC v. Austin" on Justia Law

A group of plaintiffs, including abutting property owners and a nonprofit, challenged the sale of a 21-acre cranberry bog in Centerville, Massachusetts, known as the Jenkins Bog. The land had been classified for tax purposes as horticultural use under G. L. c. 61A, which provides municipalities a right of first refusal when such land is sold for non-agricultural purposes. Susan L. Jenkins, as trustee, notified the Barnstable town manager of her intent to sell the bog to a buyer intending residential use, but failed to provide notice to other required municipal bodies and the State forester. The sale proceeded, transferring title to Bog Partners LLC. The plaintiffs learned of the sale after the fact and contended that the statutory notice requirements had not been met, seeking to invalidate the transaction and compel compliance with the statute.The plaintiffs brought their claims in Barnstable Superior Court, seeking declaratory judgment and mandamus relief. Both the Town of Barnstable and Bog Partners LLC moved for summary judgment, arguing the plaintiffs lacked standing. Two Superior Court judges granted summary judgment for the defendants on the basis of lack of standing.On appeal, the Supreme Judicial Court of Massachusetts reviewed the case. The Court held that the plaintiffs, as abutters and concerned citizens, did not have standing to seek declaratory relief under G. L. c. 231A because the statutory notice and right of first refusal provisions in G. L. c. 61A are designed to protect municipal—not private—interests. The Court also held that mandamus relief was improper because the Town had fulfilled its statutory obligation by notifying the seller of the deficient notice; any further enforcement steps were discretionary. The Supreme Judicial Court affirmed the lower court judgments in favor of the Town and Bog Partners LLC. View "Banevicius v. Barnstable" on Justia Law

Two former tenants sued the owner and manager of a residential apartment complex, alleging that they were charged unlawful rental application fees and excessive lock change fees, in violation of the Massachusetts security deposit statute and consumer protection laws. They sought to represent a statewide class of similarly situated tenants. After contentious discovery, the Superior Court sanctioned the defendants, precluding them from contesting certain liability facts. The court granted summary judgment to the plaintiffs on the security deposit claims but denied summary judgment on the consumer protection claims. Before trial, the parties reached a proposed class action settlement that established a fund for class members, with unclaimed funds to be distributed partly to charities and partly returned to the defendants.The Superior Court, after scrutiny and required revisions, approved the settlement. The court capped the amount of unclaimed funds that could revert to the defendants and required that a portion go to designated charities. However, the Massachusetts IOLTA Committee, a nonparty potentially entitled to notice under Mass. R. Civ. P. 23(e)(3), was not notified prior to settlement approval. After final approval and claims processing, the committee received notice for the first time and objected to the final distribution of unclaimed funds, arguing that the lack of timely notice violated the rule and that final judgment should be set aside. The motion judge agreed there was a violation but declined to vacate the settlement, finding no prejudice.On direct appellate review, the Supreme Judicial Court of Massachusetts held that the IOLTA Committee had standing to appeal the denial of its procedural right to notice and an opportunity to be heard on the disposition of residual funds, but lacked standing to challenge the overall fairness or structure of the settlement. Assuming a violation of the rule occurred, the Court found no prejudice because the committee ultimately received the opportunity to be heard before judgment entered. The judgment was affirmed. View "Ortins v. Lincoln Property Company" on Justia Law