Justia Massachusetts Supreme Court Opinion Summaries

Odin Anderson, his wife, and his daughter (collectively, Plaintiffs) filed personal injury action for injuries Odin suffered after being struck by a bus owned by Partners Healthcare Systems that was being driven by one of its employees. Plaintiffs then filed a separate action against Partner’s insurers and claims representatives. A jury awarded Odin $2,961,000 in damages in the personal injury action and awarded Odin’s wife and daughter $110,000 each. At a subsequent jury-waived trial, a judge found that the insurers and claims representatives violated Mass. Gen. Laws ch. 93A and Mass. Gen. Laws ch. 176D by their misconduct. The judge awarded Plaintiffs treble damages using as the “amount of the judgment” to be multiplied the combined amount of the underlying tort judgment and the accrued postjudgment interest on that judgment. The appeals court affirmed. The Supreme Judicial Court vacated the judgment, holding that, in a case where the amount of actual damages to be multiplied due to a wilful or knowing violation of Mass. Gen. Laws ch. 93A or Mass. Gen. Laws ch. 176D are based on the amount of an underlying judgment, that amount does not include postjudgment interest. View "Anderson v. National Union Fire Insurance Co. of Pittsburgh Pa." on Justia Law

Defendant was acquitted on a charge of receipt of stolen property and then prosecuted for larceny of the same property. Defendant argues that the subsequent larceny complaint was properly dismissed on the ground of double jeopardy. The court concluded that the same elements test, firmly rooted in the court's history and case law, is the only appropriate test to apply in both single and successive prosecution scenarios. The court explained that, because larceny and receipt are not the same offense for double jeopardy purposes, dismissal of the larceny complaint on double jeopardy grounds is not warranted. Finally, the court concluded that the successive prosecutions do not violate the equitable principles of due process, collateral estoppel, and judicial estoppel. Accordingly, the court reversed the allowance of defendant's motion to dismiss on the ground of double jeopardy. View "Commonwealth v. Rodriguez" on Justia Law

Plaintiff filed suit against Deutsche Bank, seeking a declaratory judgment that the bank's foreclosure of the mortgage on plaintiff's home was invalid and seeking to quiet title to the property. The superior court granted the bank's motion to dismiss. The court concluded, as did the trial court judge, that a foreclosing mortgagee's failure to comply with G. L. c. 244, § 15A, by failing to send the postforeclosure notices required by the statute, does not render the foreclosure void. In this case, where the provision in question does not set forth preforeclosure requirements that are a part of the foreclosure process, the Bank's failure to comply with section 15A's postforeclosure notice provisions did not render the foreclosure void. Accordingly, the court affirmed the judgment. View "Turra v. Deutsche Bank Trust Company Americas" on Justia Law

Petitioner filed an action alleging claims of Medicare or Medicaid fraud and retaliation by his employer when he spoke up about the purported fraud. A federal district court judge allowed a motion to dismiss certain federal defendants and then remanded the case to the superior court. Petitioner appealed. The appeal remained pending when, in the superior court, the remaining defendants filed motions to dismiss. Petitioner filed a motion in the county court that the single justice treated as a petition pursuant to Mass. Gen. Laws ch. 211, 3, arguing that the state court lacked jurisdiction because his appeal from the remand order remained pending in the federal court and seeking a stay in the superior court. A docket entry indicated that because Petitioner’s appeal remained pending, the status conference would be continued. Thereafter, the single justice denied the petition. Petitioner then filed a memorandum and appendix pursuant to S.J.C. Rule 2:21 seeking a stay in the trial court. The Supreme Court denied relief, holding that this case did not present a situation where extraordinary relief from this Court was required, and the single justice correctly denied relief under Mass. Gen. Laws ch. 211, 3. View "Padmanabhan v. Centers for Medicare & Medicaid Services" on Justia Law

Bahig Bishay brought an action bringing various claims arising from Plaintiff’s eviction from his home. Bishay named as defendants National Investigations, Inc. and its principals (collectively, National), Harvard 45 Associates, LLC and its principals (collectively, Harvard), and Allied Finance Adjusters Conference, Inc. (Allied). Allied’s motion to dismiss was allowed. Also allowed was Harvard’s motion for summary judgment as to both the claims against it and a counterclaim it asserted against Bishay. Thereafter, Bishay and National (collectively, Petitioners) settled their dispute and moved for entry of final judgment. The motion was denied. Petitioners then filed a petition seeking relief in the nature of mandamus and requesting that the clerk of the superior court be ordered to enter final judgment as Petitioners proposed. A single justice denied relief without a hearing. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused her discretion by denying extraordinary relief, as Petitioners had other remedies available to them. View "Bishay v. Clerk of the Superior Court in Norfolk County" on Justia Law

After a jury trial, Appellant was convicted of two counts of unlawful possession of a loaded firearm and one count of possession of a firearm without a license. Appellant appealed, arguing that the Commonwealth failed to demonstrate that the police had reasonable suspicion to conduct an investigatory stop of his vehicle, and therefore, the trial court erred in denying his motion to suppress. The Court of Appeals agreed with Appellant and reversed the judgments of conviction, the verdicts, and the motion to suppress, holding that the police did not have reasonable suspicion to conduct the investigatory stop. View "Commonwealth v. Pinto" on Justia Law

Defendant was one of three occupants of a vehicle that was stopped for a traffic violation. When Defendant, the rear seat passenger, exited the vehicle based on an exit order, a police officer observed a handgun underneath his right thigh. At trial, the court ordered that evidence concerning the front seat passenger’s prior conviction of unlawful possession of a firearm was excluded for all purposes. Defense counsel violated this order and proceeded to elicit this testimony anyway. The judge declared a mistrial. Thereafter, Defendant moved to dismiss the charges on double jeopardy grounds, arguing that there had been no manifest necessity to declare a mistrial. A superior court judge denied the motion. Defendant then filed a petition pursuant to Mass. Gen. Laws ch. 211, 3. The single justice concluded that the trial judge had erred in determining that there was a manifest necessity to declare a mistrial. The Supreme Judicial Court remanded the matter to the county court for entry of an order denying Defendant’s petition, holding (1) there was no abuse of discretion in the judge’s decision to declare a mistrial on the ground of manifest necessity; and (2) the single justice applied a substituted judgment standard in finding otherwise. View "Commonwealth v. Bryan" on Justia Law

Defendant was indicted for multiple firearms offenses, among other offenses. Defendant moved to suppress evidence seized during the search of a motor vehicle he had been driving. A superior court judge allowed the motion, concluding that, at the time a police officer stopped and seized the vehicle, the officer lacked a reasonable, articulable suspicion that criminal activity was afoot. The Supreme Judicial Court reversed the motion judge’s order allowing the motion to suppress, holding (1) the investigatory stop was predicated on reasonable suspicion of criminal activity; and (2) the officer’s actions were “reasonably related in scope to the circumstances which justified the interference in the first place.” View "Commonwealth v. Edwards" on Justia Law

In Bridgeman v. District Attorney for the Suffolk District (Bridgeman I), the Supreme Judicial Court declined to accept a proposed “global remedy” of vacating the thousands of drug convictions affected by the misconduct of Annie Dookhan when she was employed as a chemist at the William A. Hinton State Laboratory Institute despite the claim that the time and expense of case-by-case adjudication had become untenable. Here, the district attorneys provided the single justice with lists identifying more than 20,000 potentially aggrieved defendants based on Dookhan’s misconduct. The single justice issued a reservation and report to the full court inviting it to reconsider its previous ruling. Rather than adopting Petitioners’ request for a global remedy, the Supreme Judicial Court adopted a new protocol for case-by-case adjudication. The adjudication will occur in three phases and be implemented by the single justice in the form of a declaratory judgment. View "Bridgeman v. District Attorney for the Suffolk District" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on theories of deliberate premeditation and extreme atrocity and cruelty. The Supreme Judicial Court affirmed the jury’s verdict, holding (1) the admission of testimony by a jailhouse informant did not violate Defendant’s confrontation rights; (2) a ballistics expert properly testified to a report prepared by an unavailable expert; (3) the admission of testimony of the Commonwealth’s wire expert created no substantial likelihood of a miscarriage of justice; (4) no reversible error occurred in the admission of two types of evidence resulting from searches of Defendant’s computer; and (5) the admission of transcript of the victim’s testimony from earlier proceedings involving both Defendant and the victim was not in error. View "Commonwealth v. Caruso" on Justia Law