Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the decision of the trial judge granting Defendant’s motion for a new trial, holding that the judge did not err in concluding that an affidavit by a deceased affiant was admissible and was newly discovered evidence that cast real doubt on the justice of Defendant’s convictions.Defendant was convicted of murder in the first degree. The Commonwealth’s case against Defendant depended largely upon the testimony of James Jackson. Later, Debra Bell stated in an affidavit that Jackson could not have witnessed the shooting because he was in the bathroom with her at the relevant time. Bell died shortly after providing the affidavit. Defendant moved for a new trial, arguing that the affidavit was newly discovered evidence, but the trial judge denied the motion. The Supreme Court remanded the case for a hearing to determine whether Bell’s affidavit fell within the exception to the hearsay rule that applies where otherwise inadmissible hearsay is critical to the defense and bears persuasive guarantees of trustworthiness. On remand, a different judge determined that the affidavit fell within the exception and granted the motion for a new trial. The Supreme Judicial Court affirmed, holding that the motion judge did not err in allowing Defendant’s motion for a new trial. View "Commonwealth v. Drayton" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree on a theory of felony-murder and armed robbery and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E. The Court held (1) the trial judge violated Defendant’s right to confront witnesses by allowing the jury to be exposed to certain hearsay, but the error was harmless beyond a reasonable doubt; (2) the trial judge erred by allowing a substitute expert witnesses to testify to a match between the defendant's DNA profile and one obtained from the victim's clothing, but the error did not result in a substantial likelihood of a miscarriage of justice; (3) Defendant’s trial counsel was not ineffective; and (4) government officials did not commit unconstitutional misconduct in the course of investigating and prosecuting Defendant. View "Commonwealth v. Seino" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree on a theory of felony-murder and armed robbery and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E. The Court held (1) the trial judge violated Defendant’s right to confront witnesses by allowing the jury to be exposed to certain hearsay, but the error was harmless beyond a reasonable doubt; (2) the trial judge erred by allowing a substitute expert witnesses to testify to a match between the defendant's DNA profile and one obtained from the victim's clothing, but the error did not result in a substantial likelihood of a miscarriage of justice; (3) Defendant’s trial counsel was not ineffective; and (4) government officials did not commit unconstitutional misconduct in the course of investigating and prosecuting Defendant. View "Commonwealth v. Seino" on Justia Law

The Supreme Judicial Court affirmed the decision of the motion judge allowing summary judgment for Defendants, Massachusetts Institute of Technology (MIT) and individuals associated with MIT, in this wrongful death action arising out of the suicide of Plaintiff’s son.Plaintiff commenced this action alleging that Defendants’ negligence caused the death of his son, who was a student at MIT. Defendants’ motion for summary judgment was allowed, and Plaintiff’s cross motion for summary judgment was denied. The Supreme Judicial Court affirmed, holding (1) in certain circumstances not present in this case, a special relationship and a corresponding duty to take reasonable measures to prevent suicide may be created by a university and its student; but (2) here, the superior court properly granted summary judgment for Defendants on the tort claims as a matter of law and properly denied summary judgment on the workers’ compensation claim. View "Nguyen v. Massachusetts Institute of Technology" on Justia Law

At issue was the proper construction of the termination for convenience clause in a contract between the Massachusetts Bay Transportation Authority (MBTA) and A.L. Prime Energy Consultant, Inc. (Prime).The Supreme Judicial court held (1) a State or municipal entity may terminate a procurement contract for its convenience in order to achieve costs savings where, as in this case, the contractual language permits and in the absence of contrary applicable law; and (2) the superior court judge erred in denying MBTA’s motion to dismiss Prime’s complaint on the ground that a public entity may not invoke a termination for convenience clause in a State or municipal public procurement contract in order to secure a lower price. View "A.L. Prime Energy Consultant, Inc. v. Massachusetts Bay Transportation Authority" on Justia Law

The Supreme Judicial Court affirmed the adjudication of delinquency as to a juvenile offender under the age of sixteen, holding that, as applied in these circumstances where the juvenile maintained that he was involved in consensual experimentation with another child, enforcement of the statutory rape charge was constitutional.At the time of the alleged offenses, the juvenile was twelve years old and the victim was eight years old. A jury found the juvenile delinquent of statutory rape. On appeal, the juvenile argued that the imposition of criminal liability on a child for a strict liability offense was fundamentally unfair. The Supreme Judicial Court disagreed, holding that the juvenile’s arguments were unable to overcome the presumption that the Legislature acted reasonably and rationally in imposing strict liability for anyone who has sexual intercourse with a child under the age of sixteen. View "Commonwealth v. Wilbur W." on Justia Law

Plaintiffs, five students who attend public schools in the city of Boston, failed to state a claim for relief in their complaint alleging that the charter school cap under Mass. Gen. Laws ch. 71, 89(i) violates the education clause and the equal protection provisions of the Massachusetts Constitution because Plaintiffs were not able to attend public charter schools of their choosing.Plaintiffs sued the Secretary of Education, the chair and members of the board of secondary and elementary education, and the Commissioner of Education seeking declaratory and injunctive relief. Defendants filed a motion to dismiss. The motion judge granted the motion, concluding that Plaintiffs failed to state a claim under either the education clause or the equal protection provisions of the Massachusetts Declaration of Rights. The Supreme Judicial Court affirmed, holding (1) Plaintiffs failed to allege facts suggesting not only that they had been deprived of an adequate education but that Defendants failed to fulfill their constitutionally prescribed duty to educate; and (2) there was no plausible set of facts that Plaintiffs could prove to support a conclusion that the charter school cap did not have a rational basis. View "Doe No. 1 v. Secretary of Education" on Justia Law

Because forty-five years had passed since Petitioner’s trial, it had not been definitively adjudicated that Petitioner’s loss of his direct appeal was due to any ineffective assistance of counsel, and Petitioner had not attempted to rectify the situation through a motion for a new trial, the order of the single justice allowing Petitioner’s petition to reinstate his direct appeal was reversed.In 1972, Petitioner was convicted of two counts of murder in the first degree and one count of robbery. Petitioner’s direct appeal was never perfected. In 1992, Petitioner filed a motion seeking an order directing the superior court clerk to transmit the record to the Supreme Judicial Court so that he could pursue his direct appeal. A single justice denied the motion. In 2014, Petitioner again filed a pro se motion for leave to file a late notice of appeal and a pro se petition to reinstate his direct appeal. In 2016, a single justice allowed Petitioner’s petition to reinstate his direct appeal and allowed his motion to file a late notice of appeal. The Supreme Judicial Court reversed for the reasons set forth above. View "White v. Commonwealth" on Justia Law

The Department of Correction’s policy announced in 2013 that visitors to correctional facilities would be subject to search by drug-detecting dogs was not inconsistent with the Department’s existing regulations but was not exempt from the Administrative Procedure Act (APA), Mass. Gen. Laws ch. 31A, 1 et seq.Plaintiffs commenced this action to prevent the Department from implementing the new policy. The superior court denied Plaintiffs’ motion for a preliminary injunction, and the policy was thereafter implemented. A second superior court judge entered judgment declaring that the Commissioner of Correction had the authority o establish the policy without having to comply with the procedural requirements of the APA. The Supreme Judicial Court remanded this case to the superior court for entry of a judgment declaring that the Department was required to, but did not, meet the requirements of the APA when it adopted this regulation but that the regulation, if properly adopted in conformance with the APA, would not conflict with existing Department regulations. View "Carey v. Commissioner of Correction" on Justia Law

The Supreme Judicial Court reversed the judgment of a single justice of the county court denying the Commonwealth’s petition for relief pursuant to Mass. Gen. Laws ch. 211, 3 from an interlocutory ruling of the Boston Municipal Court Department, holding that the trial judge’s decision to deny the Commonwealth’s motion was clearly erroneous.Defendant was charged with several crimes stemming from an incident during which several individuals assaulted and robbery the victim. During the court of discovery, the Commonwealth provided Defendant with a copy of a DVD containing surveillance video. But as trial approached, the Commonwealth was unable to locate its own copy of the DVD. The day before trial, the Commonwealth moved for an order requiring Defendant to return to the Commonwealth a copy of the DVD for the Commonwealth’s use at trial. The trial judge denied the motion. The Commonwealth then filed this petition, which the single justice denied without a hearing. The Supreme Judicial Court reversed, holding that the Commonwealth’s use of Mass. Gen. Laws ch. 211, 3 was proper, and because the Commonwealth had no other remedy, the judge’s decision was clearly in error. View "Commonwealth v. Tahlil" on Justia Law