Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s convictions of human trafficking, deriving support from prostitution, and assault and battery, thus rejecting Defendant’s claims of error. The court held (1) the trial judge did not abuse her discretion in limiting defense counsel’s questioning during voir dire; (2) the evidence against Defendant was legally sufficient to sustain a conviction of human trafficking; (3) there was no error in the instruction to the jury regarding the human trafficking charge; and (4) the trial judge did not err in allowing the introduction of certain records and then retroactively ordering them to be redacted. View "Commonwealth v. Dabney" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court affirming a determination by the Contributory Retirement Appeal Board (CRAB) that sick or vacation payments, when used to supplement workers’ compensation payments, are not “regular compensation” as defined in Mass. Gen. Laws ch. 32, 1.On appeal, the Public Employee Retirement Administration Commission (PERAC) argued that CRAB erred in determining that the supplemental pay received pursuant to Mass. Gen. Laws ch. 152, 69 does not constitute “regular compensation” as defined in Mass. Gen. Laws ch. 32, 1 when received in conjunction with workers’ compensation. The Supreme Judicial Court disagreed, holding that CRAB’s decision was not incorrect as a matter of law. View "Public Employee Retirement Administration Commission v. Contributory Retirement Appeal Board" on Justia Law

A driver’s consent to allow law enforcement officers to search for narcotics or firearms “in the vehicle” does not authorize the officer to search under the hood of the vehicle and, as part of that search, to remove the vehicle’s air filter.The superior court in this case granted Defendant’s motion to suppress, concluding that the scope of Defendant’s consent for officers to search for narcotics or firearms "in the vehicle" was limited to a search for narcotics or firearms in the vehicle’s interior and did not include a search under the hood beneath the air filter. The Supreme Judicial Court affirmed, holding that the search exceeded the scope of Defendant’s consent, and therefore, the search of the air filter under the hood was unconstitutional. The court thus affirmed the motion judge’s order allowing Defendant’s motion to suppress the weapons found in the air filter and Defendant’s subsequent statements to the police related to his possession of those weapons. View "Commonwealth v. Ortiz" on Justia Law

A driver’s consent to allow law enforcement officers to search for narcotics or firearms “in the vehicle” does not authorize the officer to search under the hood of the vehicle and, as part of that search, to remove the vehicle’s air filter.The superior court in this case granted Defendant’s motion to suppress, concluding that the scope of Defendant’s consent for officers to search for narcotics or firearms "in the vehicle" was limited to a search for narcotics or firearms in the vehicle’s interior and did not include a search under the hood beneath the air filter. The Supreme Judicial Court affirmed, holding that the search exceeded the scope of Defendant’s consent, and therefore, the search of the air filter under the hood was unconstitutional. The court thus affirmed the motion judge’s order allowing Defendant’s motion to suppress the weapons found in the air filter and Defendant’s subsequent statements to the police related to his possession of those weapons. View "Commonwealth v. Ortiz" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for indecent assault and battery on a person over fourteen, assault and battery, and indecent exposure. The court held (1) the trial judge did not err in declining to give an instruction on mistake of fact for either the charge of indecent assault and battery or the charge of indecent exposure; (2) the trial judge did not err in allowing what Defendant asserted was unnecessary first complaint evidence; and (3) the trial judge did not abuse his discretion either in asking jurors follow-up questions after attorney-conducted voir dire or in ruling that the jurors were prejudicial. View "Commonwealth v. Kennedy" on Justia Law

The bus drivers in this case were not entitled to overtime payment because their employer was licensed and regulated pursuant to the common carrier statute.Plaintiff-bus drivers worked for Eastern Bus Company. Eastern Bus provided charter service, for which it must hold a license under the common carrier statute, and transportation of school students between home and school, which does not constitute charter service. The bus drivers, who performed both of these services, claimed that they were entitled to overtime payment because, among other things, the exemption to the Massachusetts overtime statute (see Mass. Gen. Laws ch. 151, 1A(11)) only applied during the hours Eastern Bus was providing charter service. The superior court concluded that Eastern Bus did not enjoy “a blanket exemption” for all employees, regardless of the particular duties they perform, that the overtime exemption did not apply, and that Plaintiffs were entitled to summary judgment on their claim for overtime wages. The Supreme Judicial Court reversed, holding that the bus drivers were not entitled to overtime payment because their employer was licensed and regulated pursuant to the common carrier statute. View "Casseus v. Eastern Bus Company, Inc." on Justia Law

Under the children requiring assistance (CRA) statute, a child “willfully fails to attend school” if the child’s repeated failure to attend school arises from reasons portending delinquent behavior.In this case, the Millis public schools filed a habitual truancy CRA alleging that M.P. was a child requiring assistance on the grounds that she was habitually truant. M.P. failed continually to attend school due to a combination of physical and mental disabilities, including a severe bladder condition and autism. After a hearing, the juvenile court adjudicated M.P. a child requiring assistance. The Supreme Judicial Court vacated the judgment and remanded the matter to the juvenile court for entry of an order dismissing the CRA petition, holding that the evidence in the record did not support a finding beyond a reasonable doubt that M.P. “willfully fail[ed] to attend school.” View "Millis Public Schools v. M.P." on Justia Law

Under the children requiring assistance (CRA) statute, a child “willfully fails to attend school” if the child’s repeated failure to attend school arises from reasons portending delinquent behavior.In this case, the Millis public schools filed a habitual truancy CRA alleging that M.P. was a child requiring assistance on the grounds that she was habitually truant. M.P. failed continually to attend school due to a combination of physical and mental disabilities, including a severe bladder condition and autism. After a hearing, the juvenile court adjudicated M.P. a child requiring assistance. The Supreme Judicial Court vacated the judgment and remanded the matter to the juvenile court for entry of an order dismissing the CRA petition, holding that the evidence in the record did not support a finding beyond a reasonable doubt that M.P. “willfully fail[ed] to attend school.” View "Millis Public Schools v. M.P." on Justia Law

The Supreme Judicial Court affirmed the trial judge’s denial of Defendant’s motion for a new trial on the grounds that he was denied the effective assistance of counsel during his criminal trial. Specifically, Defendant argued that his counsel provided ineffective assistance because counsel failed to furnish the judge with the expert testimony, scholarly articles, or treatises necessary to enable the judge to determine that the principles in Defendant’s proposed eyewitness identification instruction were generally accepted in the relevant scientific community. The trial judge found that counsel’s decision not to present expert testimony and other evidence was a tactical one that was not manifestly unreasonable. The Supreme Judicial Court agreed, holding that the judge neither erred nor abused his discretion in denying Defendant’s motion for a new trial. View "Commonwealth v. Gomes" on Justia Law

At issue was whether the holding in Commonwealth v. Newton N., also decided today, that where a prosecutor wishes to proceed to arraignment on a delinquency complaint supported by probable cause, a juvenile may not dismiss the complaint before arraignment on the grounds that dismissal is in the best interests of the child and in the interests of justice, also limits judicial authority to dismiss a delinquency complaint brought by a private party under Mass. Gen. Laws. ch. 218, 35A, where a clerk-magistrate issued the complaint after finding probable cause. The Supreme Judicial Court held (1) the limitation set forth in Newton N. applies only where the prosecutor has affirmatively adopted the private party’s complaint by moving for arraignment, rather than simply appearing at the scheduled arraignment; and (2) where the prosecutor has not moved for arraignment, a judge considering a juvenile’s motion to dismiss before arraignment may consider whether the clerk-magistrate appropriately exercised sound discretion in issuing the complaint and, in so doing, may consider whether dismissal is in the best interest of the child and in the interests of justice. View "Commonwealth v. Orbin O." on Justia Law