Justia Massachusetts Supreme Court Opinion Summaries

This interlocutory review arose out of a discovery dispute in an action brought by Plaintiff, a union member, alleging claims of employment discrimination and retaliation against Defendants. Plaintiff objected to certain discovery requests on the part of Defendants, asserting a union member-union privilege. The judge rejected Plaintiff’s claim and entered an order compelling production of the discovery. At issue on appeal was whether the Supreme Judicial Court should interpret Mass. Gen. Laws ch. 150E as implying a union member-union privilege even where no such privilege has been recognized in Massachusetts. The Supreme Judicial Court affirmed the order below, holding (1) there is no legislative intent to incorporate within Mass. Gen. Laws ch. 150E a union member-union privilege extending beyond the labor dispute setting; and (2) the Court declines to recognize the privilege under common law. View "Chadwick v. Duxbury Public Schools" on Justia Law

Karen Partanen and Julie Gallagher were in a committed, nonmarital relationship for twelve years. Using in vitro fertilization and with Partanen’s full participation and consent, Gallagher fave birth the two children. The parties jointly raised the children until their separation. Partanen subsequently filed this action to establish full legal parentage pursuant to Mass. Gen. Laws ch. 209C, 6(a)(4). Gallagher filed a motion to dismiss the complaint for failure to state a claim. A judge of the probate and family court allowed the motion, concluding that Partanen could not be deemed a presumed parent under Mass. Gen. Laws ch. 209C, 6(a)(4) because she was not the children’s biological parent. The Supreme Judicial Court reversed, holding (1) a person may establish herself as a child’s presumptive parent under the statute in the absence of a biological relationship with the child; and (2) the assertions in Partanen’s complaint were sufficient to state a claim of parentage under the statute. Remanded. View "Partanen v. Gallagher" on Justia Law

Prior to his scheduled release, the Commonwealth filed a petition to commit James Green as a sexually dangerous predator (SDP). Green was found sexually dangerous after a jury trial. Two months later, Green filed a petition for discharge pursuant to Mass. Gen. Laws ch. 123A, 9. After a trial, the jury returned their verdict that Green was not an SDP. The Commonwealth filed a motion for a new trial, challenging the trial judge’s instruction that in order to find Green sexually dangerous the jury must credit the expert opinion testimony of the qualified examiner. The trial court denied the motion. The Supreme Judicial Court affirmed, holding (1) a finding of sexual dangerousness must be based at least in part on credible qualified examiner opinion testimony; and (2) therefore, there was no error in the judge’s instruction that the jury must credit the qualified examiner’s opinion to reach a finding of sexual dangerousness. View "In re Green" on Justia Law

Defendant was stopped for failing to stop at a stop sign. The officer concluded that Defendant was using the vehicle without authority and decided to impound the vehicle. During an inventory search in preparation for impoundment, the officer seized a handgun and box of ammunition from the vehicle. Defendant was charged with unlawful possession of a firearm, unlawful possession of a loaded firearm, unlawful possession of ammunition without a firearm identification card, and unauthorized use of a motor vehicle. Defendant filed a motion to suppress the handgun, the ammunition, and statements he made to police. The municipal court allowed the motion to suppress. The Supreme Judicial Court affirmed the order allowing the motion to suppress, holding (1) the police did not have probable cause to believe that Defendant was operating the vehicle he was driving in violation of Mass. Gen. Laws ch. 90, 24(2)(a), and therefore, the impoundment of the vehicle was not proper; and (2) therefore, the inventory search was not lawful, and the handgun and ammunition were properly suppressed. View "Commonwealth v. Campbell" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation, and of unlawful possession of a firearm for the shooting death of a fifteen year old boy. Defendant received the statutorily required sentence of life imprisonment without the possibility of parole for his murder conviction. Defendant was eighteen years old at the shooting. The Supreme Judicial Court affirmed, holding (1) the trial judge did not abuse her discretion in excluding from evidence a computer-generated simulation that was intended to assist the jury in determining the shooter’s height; (2) the remainder of the trial court’s evidentiary rulings challenged on appeal were not in error; (3) the Commonwealth did not improperly invoke the jury’s sympathy during closing argument; (4) Defendant’s sentence was not unconstitutional; and (5) there was no basis on which to grant Defendant extraordinary relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Chukwuezi" on Justia Law

Defendant was charged with murder in the first degree. A superior court judge allowed Defendant’s motion to suppress evidence recovered from his cellular telephone, concluding that the seizure of the telephone was not supported by probable cause. The Supreme Judicial Court affirmed, holding (1) probable cause to search or seize a person’s cellular telephone may not be based solely on an officer’s opinion or belief that the device is likely to contain evidence of the crime under investigation; (2) because the officers in this case lacked any information establishing the existence of relevant evidence likely to be found on Defendant’s telephone, the seizure was not supported by probable cause; and (3) the Commonwealth did not meet its burden of demonstrating that the sixty-eight-day-delay between the seizure and the application for a search warrant was reasonable. View "Commonwealth v. White" on Justia Law

After a jury trial, Defendant was convicted of two counts of criminal harassment. The convictions were based on five letters that Defendant wrote and sent to Michael and Susan Costello after a local election in which Michael had been elected as a town selectman. The Supreme Court reversed and dismissed Defendant’s conviction of criminal harassment of Michael and vacated Defendant’s conviction of criminal harassment of Susan and remanded for a new trial on that count, holding (1) in light of First Amendment constitutional protections afforded to political speech and the lack of evidence of serious alarm of Michael’s part, the evidence was not sufficient to support Defendant’s conviction of criminal harassment of Michael; and (2) the speech on which the complaint of criminal harassment of Susan is premised might be found to qualify as fitting within a constitutionally unprotected category of speech that may be subject to prosecution as a form of criminal harassment. View "Commonwealth v. Bigelow" on Justia Law

A landlord (Defendant) was convicted of assault and battery for pushing a Muslim tenant down a flight of stairs. Defendant was sentenced to a two-year term of incarceration, six months to serve, with the balance suspended for a period of two years. As special conditions of her probation, Defendant was required to provide a written disclosure to prospective tenants that she had been convicted of assaulting a tenant and to attend an introductory class on Islam. The Supreme Judicial Court affirmed, holding (1) the trial judge did not abuse his discretion in imposing the sentence of incarceration or in requiring Defendant to provide written disclosure to prospective tenants as a condition of probation; (2) Defendant’s constitutional objections to attending the class on Islam as a condition of probation were waived; and (3) the remainder of Defendant’s allegations of error failed. View "Commonwealth v. Obi" on Justia Law

After a jury-waived trial, Defendant was convicted of unlawful possession of a firearm. Defendant appealed the denial of his motion to suppress a firearm and statements he made after his arrest, arguing that the police lacked reasonable suspicion to make an investigatory stop of him in connection with a breaking and entering that had occurred in a nearby home approximately thirty minutes earlier. The Appeals Court affirmed. The Supreme Judicial Court vacated the conviction, holding that the trial court erred in denying Defendant’s motion to suppress because the police lacked reasonable suspicion for the investigatory stop. Remanded. View "Commonwealth v. Warren" on Justia Law

After a jury trial, Defendant was convicted of, among other crimes, murder in the first degree on a theory of felony murder, based on the predicate felony of armed robbery. The Supreme Judicial Court vacated Defendant’s armed robbery conviction and affirmed his remaining convictions, holding (1) Defendant’s armed robbery conviction was the predicate felony for his felony-murder conviction, the only theory on which the jury found Defendant guilty of murder in the first degree, and therefore, the armed robbery conviction was duplicative; and (2) no other prejudicial error occurred during Defendant’s trial, and there was no other basis to exercise the Court’s authority pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Carter" on Justia Law