Justia Massachusetts Supreme Court Opinion Summaries

In this case filed by a Massachusetts-based company (“LevelUp”) against a California-based company (“Punchh”), alleging defamation and related causes of action connected with Punchh’s allegedly false statements about LevelUp to LevelUp’s prospective clients, the superior court allowed Punchh’s motion to dismiss on the grounds that it would not comport with due process to hale Punchh into a Massachusetts court. The Supreme Judicial Court remanded this matter to the superior court for further proceedings, holding (1) prior to exercising personal jurisdiction over a nonresident defendant, a judge must determine that doing so comports with both the forum’s long-arm statute and the requirements of the United States Constitution; and (2) the requisite statutory analysis did not occur in this case. View "SCVNGR, Inc. v. Punchh, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner’s petition pursuant to Mass. Gen. Laws ch. 211, 3 asking the court to stay an order of the probate and family court appointing a temporary guardian for her adult son. The single justice denied the petition on the basis that Petitioner had an adequate alternative remedy - to seek a stay in the trial court and then, if the request were denied, to challenge that denial or make a renewed request for a stay in the appeals court. The Supreme Judicial Court affirmed, holding that this case did not present an exceptional circumstance that required this court to exercise its extraordinary power of general superintendence pursuant to Mass. Gen. Laws ch. 211, 3. View "In re Guardianship of Lado" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court dismissing as moot the petition filed by the Lawyers’ Committee for Civil Rights and Economic Justice seeking declaratory and injunctive relief requiring Respondents - the court administrator, office of court management, and executive office of the trial court - to produce certain records pursuant to the public records law, Mass. Gen. Laws ch. 66, 10. The Lawyers’ Committee specifically requested that Respondents produce documents concerning the demographics of the security department of the trial court, by race and gender, and the department’s hiring and promotion practices. Respondents eventually produced the documents that were responsive to the Lawyers’ Committee’s request. The Supreme Judicial Court held that, under the circumstances, the single justice properly dismissed the petition as moot, as no further effective relief could be granted. View "Lawyers' Committee for Civil Rights and Economic Justice v. Court Administrator of the Trial Court" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions of masked armed robbery and of being a subsequent offender, holding (1) Defendant failed to establish by a preponderance of the evidence that a showup identification procedure was so unnecessarily suggestive and conducive to misidentification as to deny him the due process of law; and (2) the trial judge did not commit prejudicial error in denying Defendant’s motion to preclude the victim from making an in-court identification. In so holding, the court declined to extend its holding in Commonwealth v. Collins, 21 NE 3d 528 (Mass. 2014) to preclude all in-court identifications preceded by out-of-court showup identification procedures. View "Commonwealth v. Dew" on Justia Law

The Supreme Judicial Court affirmed the trial judge’s denial of Defendant’s motion for postconviction testing of evidence, holding that thad Defendant failed to establish, by a preponderance of the evidence, that his motion met the requirements of Mass. Gen. Laws ch. 278A, 7(b)(3) and (4).Defendant sought testing of four cigarette butts collected by investigators near the crime scene. The trial judge found that Defendant failed to meet his burden under Mass. Gen. Laws ch. 178A, 7(b) to establish that a reasonably effective defense attorney would have sought testing of the evidence, and that DNA testing had the potential to result in evidence material to the identity of the perpetrator. The Supreme Judicial Court affirmed, holding that the trial judge did not abuse her discretion in denying Defendant’s motion. View "Commonwealth v. Moffat" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty and the denial of Defendant’s motion for a new trial, holding that Defendant’s motion to suppress his confession was properly denied.Following a police interview lasting nearly five hours, Defendant confessed to having killed his mother. Defendant filed a motion to suppress his statement as involuntary. The trial court denied the motion to suppress. On appeal, Defendant argued that the waiver of his Miranda rights was involuntary, that his confession was obtained absent a valid waiver of his right to prompt arraignment, that his confession was coerced, that he was arrested without probable cause, and that his counsel was ineffective not not seeking suppression on certain grounds. The Supreme Judicial Court affirmed the conviction and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or reduce the degree of guilt, holding that the trial judge committed no error warranting reversal, and there was no constitutionally ineffective assistance by trial counsel. View "Commonwealth v. Cartright" on Justia Law

Here the Supreme Court answered a certified question from the United States District Court for the District of Massachusetts concerning the priority of coverage of two automobile insurance policies that both covered a single motor vehicle accident. A portion of the loss was covered by a primary insurance policy from an insurance company not a party to this case. The two policies at issue were triggered, according to the language in each policy, after the exhaustion of the primary policy. Each policy stated that it provided “excess” coverage and also contained an “other insurance” clause. In this opinion, the Supreme Court ultimately concluded that both excess policies covered the accident equally, after exhaustion of the underlying primary policy, to the extent of their respective policy limits. View "Great Divide Insurance Co. v. Lexington Insurance Co." on Justia Law

The Supreme Judicial Court reversed Defendant’s convictions of involuntary manslaughter and assault and battery and remanded the case for a new trial.On appeal, Defendant argued that the trial judge committed reversible error by failing to conduct a voir dire after the prosecutor reported that some jurors fell asleep during the trial. The Supreme Judicial Court held that Defendant met his burden to show that the judge’s response to the information about the sleeping jurors was a structural error that could not be considered harmless, and therefore, Defendant’s convictions must be vacated. View "Commonwealth v. Villalobos" on Justia Law

Under the Security Deposit Act, Mass. Gen. Laws ch. 186, 15B, the treble damages provision in section 15B(7) does not apply to a landlord’s violation of the requirements for an itemized list set out in section 15B(4)(iii), second-degree sentence, or to the amount forfeited for violation of section 15B(6)(b).At issue in this certified question was whether a tenant is entitled to treble the amount of his entire security deposit under section 15B(7) where a landlord fails to provide to the tenant a statement of damages that meets the statutory requirements, see section 15B(4)(iii), second sentence, thereby forfeiting the entire security deposit, see section 15B(6)(b), and also fails to return that forfeited deposit within thirty days after the tenancy’s termination. The Supreme Court answered the certified question in the negative, holding (1) a landlord violates section 15B(6)(e) only where she fails to return or account for any portion of the security deposit within thirty days, or where the landlord makes a deduction that does not fall within the categories authorized by section 15B(4)(i), (ii), (iii), first sentence; and (2) a violation of section 15(6)(e) does not apply to any portion of the security deposit that was forfeited under another provision of section 15B(6). View "Phillips v. Equity Residential Management, LLC" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on a theory of deliberate premeditation and declined to grant relief under Mass. Gen. Laws ch. 278, 33E. On direct appeal, the court held (1) the trial judge did not err in denying Defendant’s motion to suppress certain computer evidence; (2) the trial judge did not abuse her discretion in declining to exclude evidence related to Defendant’s computer username and Internet search results, Defendant’s prior bad acts, and the victim’s statements and e-mail messages; (3) any misstatement made by the prosecutor during closing argument was not so great that it created a substantial likelihood of a miscarriage of justice; and (4) the trial judge’s instruction to the jury permitting them to infer an intent to kill based on the use of poison properly instructed the jury on the use of dangerous weapons. View "Commonwealth v. Keown" on Justia Law