Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree on a theory of deliberate premeditation and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E to reduce the degree of guilt or to order a new trial. The Court held (1) any error committed by trial counsel during trial did not alter the jury’s verdict, and therefore, Defendant received constitutionally effective assistance of counsel; and (2) testimony elicited from the medical examiner did not violate Defendant’s right of confrontation pursuant to the Sixth Amendment. View "Commonwealth v. Montrond" on Justia Law

Plaintiff filed suit against the City, seeking enforcement of the Department of Industrial Accidents' (DIA) order to restore plaintiff's workers' compensation payments. The City suspended plaintiff's payments under the suspension statute, G.L. c. 268A, 25, after it learned that plaintiff had been indicted on charges related to misuse of controlled substances. The Massachusetts Supreme Judicial Court held that workers' compensation benefits are not "compensation" as defined in the suspension statute, because they are not payments made "in return for services rendered." Therefore, the Superior Court actions brought by plaintiff to enforce the orders of the DIA were dismissed in error. The Massachusetts Supreme Judicial Court reversed and remanded. View "Benoit v. City of Boston" on Justia Law

Plaintiff, who pleaded guilty to murder in the second degree and was sentenced to life imprisonment with the possibility of parole, filed a petition for parole, which the Parole Board denied. Plaintiff filed a complaint in the nature of certiorari alleging that the board violated the Americans with Disabilities Act and cognate state provisions. The superior court allowed the board’s motion to dismiss. The Supreme Judicial Court reversed, holding (1) the motion judge erred in allowing the board’s motion to dismiss because the board failed first to file the administrative record pursuant to a standing order of the superior court; and (2) contrary to Plaintiff’s assertion, Plaintiff’s commuted life sentence remains a “life sentence” within the meaning of 120 Code Mass. Regs. 301.01(5). The court remanded the case for further development of the record. View "Crowell v. Massachusetts Parole Board" on Justia Law

The term “bodily injury” as used in Mass. Gen. Laws ch. 126, 18A and Mass. Gen. Laws ch. 30, 58 is that which results in physical injury. Through these two statutes, correction officers are granted additional compensation if the employee sustains bodily injury as a result of inmate violence during the course of his or her duties. Plaintiff, a correction officer, sued the sheriff, the sheriff’s department, and the Commonwealth to obtain compensation under the statutes. Plaintiff’s symptoms were an accelerated heart rate accompanied by light-headedness and difficulty breathing. The Supreme Judicial Court affirmed the judgment of the superior court, holding that while Plaintiff may well have sustained an injury, he failed to show that he had a bodily injury within the meaning of chapter 126, section 18A. View "Modica v. Sheriff of Suffolk County" on Justia Law

Washington commenced a medical malpractice action in a federal district court against Maryjo Gagliani. A medical malpractice tribunal reviewed the case and found for Gagliani. Washington then moved the superior court to reduce the amount of the bond required for him to pursue his claim in the face of an adverse tribunal ruling. The superior court denied the motion. Washington filed a notice of appeal, but the notice was never processed. The superior court, meanwhile, allowed Gagliani’s motion to dismiss Washington’s complaint for failure to post the bond. The matter was then transferred back to the federal court. The federal court allowed Gagliani’s motion to dismiss due to Washington’s failure to post a bond. Washington filed a Mass. Gen. Laws ch. 211, 3 petition seeking relief from the superior court’s “failure to docket and recognize his appeal of” the tribunal’s ruling. A single justice denied relief. The Supreme Judicial Court affirmed, holding that the superior court and appeals court had no jurisdiction after the tribunal’s ruling to act further with respect to that ruling. Washington could not pursue his claim and challenge the tribunal’s ruling in the federal courts. View "Washington v. Gagliani" on Justia Law

In 2010, the Secretary of the Executive Office of Administration and Finance submitted to the legislature a request for an appropriation to fund collective bargaining agreements between the Commonwealth and two public employee unions reached more than one year earlier. The Department of Labor Relations concluded that by including information about anticipated fiscal effects of a legislative decision to fund collective bargaining agreements in his request for an appropriation, the Secretary violated its Mass. Gen. Laws ch. 150E, 7(b) duty and committed a prohibited practice under Mass. Gen. Laws ch. 150E, 10(a)(5) by failing to bargain in good faith. The Commonwealth Employment Relations Board affirmed. The Supreme Judicial Court reversed, holding that the Secretary did not violate section 7(b) or commit a prohibited practice in violation of section 10(a)(5). View "Commissioner of Administration & Finance v. Commonwealth Employment Relations Board" on Justia Law

The decision in Pinti v. Emigrant Mortgage Co. applies in any case where the issue was timely and fairly asserted in the trial court or on appeal before July 17, 2015. In Pinti, the Supreme Judicial Court held that a foreclosure by statutory power of sale is invalid unless the notice of default strictly complies with paragraph 22 of the standard mortgage. The court concluded that this decision should be given prospective effect only but left open the question of whether the holding should be applied to any case pending in the trial court or on appeal. In reaching that question in this case, the court concluded that Defendants timely and fairly raised this issue in the housing court before July 17, 2015. The court affirmed the judge’s ruling declaring the foreclosure sale in this case void because the notice of default did not strictly comply with the requirements in paragraph 22 of the mortgage. View "Federal National Mortgage Ass’n v. Marroquin" on Justia Law

In 1983, Defendant was convicted of one count of arson in a dwelling house and eight counts of murder in the second degree. In 2012, Defendant filed a motion for a new trial, asserting newly discovered evidence regarding the conditions under which he confessed to the crime and recent fire research. A superior court judge allowed the motion, concluding that the newly discovered evidence cast real doubt on the justice of Defendant’s convictions. The Supreme Judicial Court affirmed, but on different grounds, holding that, under the totality of the judge’s findings and the confluence-of-factors analysis developed subsequent to her decision in this case, the judge did not abuse her discretion in concluding that justice was not done in this case. View "Commonwealth v. Rosario" on Justia Law

The Supreme Judicial Court clarified the application of the Florida v. Jardines warrant requirement to a search in a multifamily home. The Court held (1) the side yard of Defendant’s multifamily home in this case was a “constitutionally protected area," and law enforcement’s intrusion into that area to search for a weapon implicated the constitutional warrant requirement; and (2) the superior court properly allowed Defendants’ motions to suppress the loaded sawed-off shotgun found under the porch because the warrantless intrusion here was an unlawful physical intrusion into the curtilage of the residence, therefore violating the warrant requirement of the Fourth Amendment and article 14 of the Massachusetts Declaration of Rights. View "Commonwealth v. Leslie" on Justia Law

The Supreme Judicial Court interpreted one provision in the habitual criminal statute, Mass. Gen. Laws ch. 279, 25(a), which provides for an enhanced penalty where a defendant has two prior convictions resulting in prison sentences of three or more years, to require that the underlying convictions arise from separate incidents or episodes of criminal behavior. In so holding, the Court affirmed the superior court order dismissing the habitual offender portions of the indictments currently pending against Defendant, holding that the Commonwealth failed to provide the grand jury with sufficient evidence to support the habitual offender portions of the indictments. View "Commonwealth v. Garvey" on Justia Law