Justia Massachusetts Supreme Court Opinion Summaries

Defendant was charged with murder in the first degree. Defendant filed a motion to suppress statements he made at two police stations, arguing that he did not knowingly and intelligently waive his Miranda rights and that the statements were not made voluntarily. Defendant then moved to impound a video recording and transcript of a police interview with Defendant that was the subject of the motion to suppress and that was subsequently suppressed. A superior court judge orally denied the motion to impound. A single justice of the Appeals Court denied Defendant’s request for interlocutory relief. A single justice of the Supreme Judicial Court vacated the denial of the motion to impound, concluding that the single justice committed an error of law and abused his discretion in affirming the judge’s denial of the motion to impound. The Supreme Judicial Court affirmed the motion judge's denial of the motion to impound, holding (1) the motion judge applied the correct legal standard in deciding Defendant’s motion to impound; and (2) the motion judge did not abuse his discretion in denying the motion to impound. View "Commonwealth v. Chism" on Justia Law

The school zone statute punishes individuals who commit certain enumerated drug offenses within 300 feet of a school or 100 feet of a public park or playground. Defendant was a passenger in a motor vehicle that was driven on a public roadway past a public park and stopped at a red light. When the light turned green, law enforcement officers stopped the vehicle, at which point the vehicle was no longer within 100 feet of the public park. The officers searched the vehicle and found drugs and a firearm. Defendant was arrested and charged with a number of offenses, including committing a drug offense within one hundred feet of a public park, in violation of Mass. Gen. Laws ch. 94C, 32J. Defendant moved to dismiss the park zone charge, arguing that the school zone statute is unconstitutional as applied to him. The judge allowed the motion. The Supreme Court affirmed, holding that application of Mass. Gen. Laws ch. 94C, 32J to Defendant, under the facts and circumstances of this case, would be overreaching. View "Commonwealth v. Peterson" on Justia Law

After a jury trial, Defendant was convicted of open and gross lewdness and lascivious behavior and resisting arrest. The Appeals Court affirmed. The Supreme Judicial Court (1) affirmed the judgment of conviction of resisting arrest; but (2) reversed the judgment of conviction of open and gross lewdness and lascivious behavior, holding that there was insufficient evidence that Defendant’s conduct caused any person to experience “shock” or “alarm,” as required by Mass. Gen. Laws ch. 272, 16. Because Defendant did not challenge the sufficiency of the evidence with respect to the first four elements of open and gross lewdness and lascivious behavior, the case was remanded for entry of a conviction of the lesser included offense of indecent exposure. View "Commonwealth v. Maguire" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of felony murder, armed home invasion, and armed assault with intent to rob. Defendant filed a motion for a new trial on the ground that the trial judge should have provided the jury with a felony murder merger instruction. The trial judge granted the motion as to the felony murder conviction but did not disturb Defendant’s remaining convictions. At Defendant’s retrial, a second jury found Defendant not guilty of the single charge of felony murder. In this appeal, Defendant argued, inter alia, that he cannot be guilty of his armed home invasion and armed assault with intent to rob convictions because the second jury acquitted him of felony murder predicated upon the same underlying felonies. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) the second trial cannot spare Defendant from the consequences of convictions properly decided by a different jury; and (2) Defendant’s claims of error in the first trial were unavailing. View "Commonwealth v. Resende" on Justia Law

Plaintiff brought this action against Nationstar Mortgage, LLC and Fremont Investment and Loan (collectively, Defendants) alleging that Defendants violated his rights under Mass. Gen. Laws ch. 93A. The Appeals Court reversed, concluding that there was a genuine issue of material fact as to Plaintiff’s chapter 93A claim. Nationstar appealed, arguing that Plaintiff’s claim was barred because he failed to serve a demand letter. The Supreme Judicial Court agreed with the Appeals Court, holding that, if a defendant keeps assets in the Commonwealth but does not maintain a place of business in the Commonwealth, the plaintiff need not serve a demand letter. View "Moronta v. Nationstar Mortgage, LLC" on Justia Law

Christine DeFelice, a part-time employee for the Stoneham school department, sought retroactive membership in the Stoneham retirement system based on a nine-week period during which she worked over thirty hours per week. The municipal retirement board granted DeFelice retroactive membership in the retirement system for the nine-week period but denied her membership for the subsequent time during which she remained a part-time employee. The Contributory Retirement Appeal Board reversed, concluding that the board was statutorily precluded from terminating the membership of individuals who had been granted membership in a retirement system and continued working for the same municipal employer. The superior court reversed. The Supreme Judicial Court reversed, holding (1) a municipal retirement board does not possess absolute discretion to terminate a part-time employee’s membership in a retirement system to which that board has granted the employee membership; and (2) a “separation from [an employee’s] service” under Mass. Gen. Laws ch. 32, 3(1)(a)(i) does not occur when a part-time employee working two jobs for the same municipal employer ceases to work only one of those jobs. View "Retirement Board of Stoneham v. Contributory Retirement Appeal Board" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of extreme atrocity or cruelty. The Supreme Judicial Court affirmed and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) Defendant has not shown that the presence of police officers during the grand jury proceedings caused a substantial likelihood of a miscarriage of justice; (2) the trial judge did not err in denying Defendant’s motion for the appointment of a special prosecutor; (3) the trial judge did not commit prejudicial error in its evidentiary rulings challenged by Defendant; (4) statements made by the prosecutor during his opening statement and closing argument did not warrant reversal; and (5) the trial judge did not abuse his discretion in denying Defendant’s motion for a new trial. View "Commonwealth v. Holley" on Justia Law

Plaintiffs contracted with Defendants through small corporations that Plaintiffs apparently formed for this purpose. Plaintiffs, who performed services in Massachusetts as furniture delivery drivers, brought a putative class action against Defendants under the independent contractor statute, claiming that they had been misclassified as independent contractors. The trial judge granted summary judgment for Defendants on the ground that the Federal Aviation Administration Authorization Act (FAAAA) preempted the independent contractor statute in its entirety. The Supreme Judicial Court vacated the grant of summary judgment, holding (1) while a portion of the independent contractor statute is preempted by the FAAAA, the remainder is severable and remains applicable to Plaintiffs’ misclassification claim; and (2) summary judgment dismissing the misclassification claim is not warranted on the separately asserted basis that Plaintiffs lack standing as individuals to assert claims for misclassification under the statute. View "Chambers v. RDI Logistics, Inc." on Justia Law

The Department of Mental Health (DMH) submitted a proposal to the Auditor of the Commonwealth that would privatize certain of its state-run mental health services. The Auditor issued a written decision approving the proposed privatization contract, concluding that the privatization proposal met the requirements of the Pacheco Law. The Pacheco Law establishes procedures that agencies must follow when beginning the bidding process for an entering into a privatization contract. The Supreme Judicial Court affirmed the Auditor’s decision, holding that the Auditor did not abuse her discretion in determining that DMH’s privatization proposal met the requirements of the Pacheco Law. View "Service Employees International Union, Local 509 v. Auditor of the Commonwealth" on Justia Law

In a four-count complaint, Defendant was charged with several criminal offenses. Defendant pleaded guilty as to counts one and four. The municipal court judge dismissed counts two and three for lack of probable cause. The Commonwealth appealed. The Appeals Court reversed the dismissal of these counts. The Supreme Judicial Court affirmed, holding that, while Defendant conceded that probable cause existed to support counts two and three, the complaint was also adequate to charge Defendant with each offense and to establish jurisdiction in the municipal court. View "Commonwealth v. Hardin" on Justia Law