Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of murder in the first degree on a theory of deliberate premeditation and of the unlawful possession of a firearm. Defendant appealed, alleging error in (1) the denial of his motions to suppress certain evidence; (2) the denial of his motion for a new trial; and (3) the admission of certain evidence at trial. The Supreme Judicial Court affirmed, holding (1) the motion judge erred in denying Defendant’s motion to suppress certain evidence after Defendant failed to appear at the scheduled motion hearing, but the denial of the motion did not create a substantial likelihood of a miscarriage of justice; (2) the trial judge did not err in denying Defendant’s motion for a new trial after the jurors were exposed to extraneous material during deliberations; and (3) there was no error in the admission of certain evidence at Defendant’s trial. View "Commonwealth v. Miller" on Justia Law

The Department of Public Utilities issued an order determining that the plain language of Mass. Gen. Laws ch. 164, 94A provides the Department with the statutory authority to review and approve ratepayer-backed, long-term contracts entered into by electric distribution companies for additional natural gas pipeline capacity in the Commonwealth. Plaintiffs filed separate petitions asking that the order be set aside on the ground that it was based on an erroneous interpretation of law. The Supreme Judicial Court vacated the Department’s order, holding (1) the order of the Department is a properly promulgated rule or regulation; but (2) the order is invalid in light of the statutory language and purpose of section 94A, as amended by the 1997 Restructuring Act, because it would undermine the main objectives of the Act. View "ENGIE Gas & LNG LLC v. Dep’t of Pub. Utils." on Justia Law

Defendant, who was admitted to the United States as a lawful permanent resident alien, pleaded guilty to an indictment alleging larceny of a motor vehicle. Defendant later moved to withdraw the guilty plea and vacate the conviction, arguing that the judge accepted his plea without advising him that the guilty plea might have the consequences of exclusion from admission to the United States. The judge denied the motion. The Appellate Court affirmed, concluding (1) the Commonwealth failed to prove that Defendant received the required warning regarding exclusion from admission to the United States; but (2) Defendant failed to show that he faced the consequence of exclusion. The Supreme Judicial Court vacated Defendant’s conviction, holding (1) a defendant satisfies the burden of showing that his conviction may have the consequences of exclusion from admission to the United States by showing that he has a bona fide desire to leave the country and reenter and that, if he were to do so, there would be a substantial risk that he would be excluded from admission because of his conviction; and (2) Defendant here met this burden, and because Defendant was not warned of this consequence during his plea colloquy, his conviction must be vacated. View "Commonwealth v. Valdez" on Justia Law

Defendant was arrested for operating while under the influence of intoxicating liquor. Defendant was not given an opportunity to consult with counsel before being required to decide whether to submit to a breathalyzer test. Defendant moved to suppress the results of the breathalyzer test, arguing that she had a right to counsel before deciding whether to submit to the breathalyzer test. After an evidentiary hearing, the district court reported a question of law asking whether the 2003 amendment to Mass. Gen. Laws ch. 90, 24, the statute establishing the offense of driving while under the influence of intoxicating liquor, now makes the decision by a defendant whether or not to take a breath test is a critical stage of the criminal proceedings requiring that the defendant be advised of his or her right to counsel prior to making that decision. The Supreme Judicial Court answered the reported question in the negative, holding that there is no right to counsel under the Sixth Amendment to the United States Constitution or article 12 of the Massachusetts Declaration of Rights before a defendant decides whether to submit to a breathalyzer test. View "Commonwealth v. Neary-French" on Justia Law

In Suffolk I, the Supreme Judicial Court held that Reading Co-Operative Bank (Bank) was allowed to require Suffolk Construction Company, Inc. (Suffolk) to perform fully Suffolk’s obligations pursuant to a collateral assignment of payments under a subcontract between Suffolk and Benchmark Mechanical Systems, Inc. (Benchmark) to secure a debt owed by Bankmark to the Bank. Suffolk subsequently commenced this action to recover the surplus that resulted when the Bank applied that collateral to satisfy Benchmark’s debt. Suffolk’s equitable claims for implied subrogation and implied indemnification were dismissed for failure to state a claim, and Suffolk’s common-law claims were dismissed as time-barred. The Supreme Judicial Court affirmed in part and reversed in part, holding (1) Suffolk’s common-law claims were time-barred; but (2) Suffolk stated viable equitable claims to prevent Benchmark’s potential windfall and unjust enrichment for which relief can be granted. View "Suffolk Constr. Co., Inc. v. Benchmark Mechanical Sys., Inc." on Justia Law

After a jury trial, Defendant was convicted of armed robbery while masked. The trial judge granted Defendant’s motion for a mistrial, determining that a series of the prosecutor’s statements made during closing argument constituted prejudicial error. The Commonwealth appealed, arguing that, although an order granting a mistrial is generally not appealable, the Supreme Judicial Court had jurisdiction to hear the appeal because the motion was granted after the verdict and thus was equivalent to a motion for relief from a guilty verdict under the Massachusetts Rules of Criminal Procedure. The Supreme Judicial Court dismissed the appeal, holding that the trial judge’s order granting Defendant’s motion for a mistrial was not appealable. View "Commonwealth v. Brangan" on Justia Law

Petitioner was convicted of murder in the first degree. Petitioner was a juvenile when the crime was committed. Thirty years later, the Supreme Judicial Court determined that any juvenile offender who had been convicted of murder in the first degree and sentenced to life in prison without the possibility of parole became eligible for parole within sixty days before the expiration of fifteen years of his life sentence. Therefore, Petitioner became immediately eligible to be considered for parole. Four out of seven members of the parole board panel voted in favor of parole. The parole board refused to grant a parole permit because, pursuant to a 2012 amendment to Mass. Gen. Laws ch. 127, 133A, a parole permit can only be granted by a vote of two-thirds of the parole board members on the panel. Petitioner appealed, arguing that the application of the amendment to his parole determination, rather than the version in effect at the time he committed the crime, was an ex post facto violation. The Supreme Judicial Court reversed the parole board’s decision, holding (1) the supermajority amendment was applied retroactively to Petitioner; and (2) the amendment was, as applied to Petitioner, an ex post facto violation. View "Clay v. Massachusetts Parole Board" on Justia Law

Plaintiff sustained a knee injury while working for the Department of Correction. Plaintiff initially received workers’ compensation benefits, as well as assault pay, but after Plaintiff was separated from employment due to a finding that he was medically unfit for duty, the Department stopped paying assault pay. Plaintiff then commenced this action seeking a declaration that he was entitled to continue receiving assault pay for so long as he was receiving workers’ compensation benefits. The superior court agreed and ordered that judgment enter declaring that Plaintiff was entitled to assault pay retroactive to the date of his separation from employment. The Supreme Judicial Court reversed, holding that a Commonwealth employee’s right to assault pay ceases with his or her separation from employment. View "Marchand v. Dep’t of Corr." on Justia Law

Defendant was convicted of criminal offenses in 2008. The Appeals Court affirmed. In 2012, the trial judge granted Defendant’s second motion for a new trial. The Appeals Court reversed, effectively reinstating Defendant’s convictions. The Supreme Judicial Court denied Defendant’s application for further appellate review. Defendant then filed a petition in the county court requesting that the single justice stay the reinstatement of his sentences pending a ruling on a petition for certiorari that he had filed in the United States Supreme Court. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice correctly denied the petition. View "Felton v. Commonwealth" on Justia Law

Defendant pleaded guilty to two counts of distribution of cocaine. The substances were subsequently tested at the William A. Hinton State Laboratory Institute, and Annie Dookhan was one of two assistant analysts who signed the drug certificates. After Dookhan’s misconduct had been discovered, Defendant moved for a new trial, seeking to vacate his guilty pleas on the ground of Dookhan’s misconduct. The trial court denied the motion. The Supreme Judicial Court affirmed, holding that there was no basis to find that governmental misconduct occurred prior to the acceptance of Defendant’s guilty pleas or that any governmental misconduct rendered Defendant’s guilty pleas unintelligent or involuntary. View "Commonwealth v. Ruffin" on Justia Law