Justia Massachusetts Supreme Court Opinion Summaries

After a second trial, a jury found Defendant guilty of two counts of murder in the first degree. Defendant later filed a motion for a new trial on the basis of new DNA evidence. The motion judge denied the motion without a hearing. Defendant filed a gatekeeper petition pursuant to Mass. Gen. Laws ch. 278, 33E, and was granted leave to appeal the denial of the motion to the full court. The Supreme Judicial Court vacated the order denying the motion and remanded for further findings. After a nonevidentiary hearing, the motion judge again denied Defendant’s motion for a new trial. Defendant filed a notice of appeal and a petition in the county court to reinstate his appeal in the full court. A single justice treated Defendant’s petition to reinstate his appeal as a second gatekeeper petition and denied the petition. Defendant then filed a motion in the full court to reinstate his appeal. The Supreme Judicial Court affirmed the order denying Defendant’s motion for a new trial, holding (1) the reinstatement of Defendant’s appeal was appropriate; and (2) the motion judge did not abuse his discretion in denying Defendant’s motion for a new trial. View "Commonwealth v. DiBenedetto" on Justia Law

Limoliner Inc., which owned and operated a fleet of luxury motor coaches, hired Dattco, Inc. to perform repair work on one of those vehicles. While Dattco recorded most of those requests in writing, Dattco neglected to write down Limoliner’s verbal request to repair one of the vehicle’s important electrical components. When Dattco failed to make any repairs to that component, Limoliner commenced this action, alleging, inter alia, that Dattco violated Mass. Gen. Laws ch. 93A, 2(a), as interpreted by 940 Code Mass. Regs. 5.05(2), by failing to record Limoliner’s request in writing. Dattco removed the case to federal court on the basis of diversity jurisdiction. Following a jury-waived trial, a magistrate judge found for Dattco on Limoliner’s regulatory claim under 940 Code Mass. Regs. 5.05, concluding that the provision at issue applies only to consumer transactions and not to transactions where the customer is another business. Limoliner appealed, and the United States Court of Appeals for the First Circuit certified a question regarding the issue to the Supreme Court. The Supreme Court answered that 940 Code Mass. Regs. 5.05 does apply to transactions in which the customer is a business entity. View "Limoliner, Inc. v. Dattco, Inc." on Justia Law

After a jury trial, Defendant was convicted as a joint venturer of murder in the first degree on a theory of deliberate premeditation. The conviction was based on evidence that Defendant had been the driver of the vehicle that dropped off at an intersection four people who shot the victim. Defendant appealed, arguing that the trial judge erred in denying her motion for a required finding of not guilty. The Supreme Judicial Court reversed, holding that Defendant’s motion for a required finding of not guilty should have been granted because the evidence was insufficient to allow a jury to conclude, beyond a reasonable doubt, that Defendant was the driver of the vehicle or that she was in some way involved in the shooting. View "Commonwealth v. Gonzalez" on Justia Law

In this case the Supreme Judicial Court recognized the “continuing treatment doctrine” under Massachusetts law, which provides that a medical malpractice cause of action does not accrue while a patient is continuing to receive treatment for the same or related condition from the same physician who allegedly caused the patient harm. Here Plaintiffs, on behalf of their minor son, brought a medical malpractice action against Defendant-physician for his alleged negligence in connection with a “radio frequency ablation” procedure he performed on their son that eventually resulted in the amputation of the child’s leg. The jury rendered a verdict in favor of Defendant, finding that the action was barred by the relevant statute of limitations because Plaintiffs knew or reasonably should have known that their son had been harmed by the Defendant’s conduct more than three years before Plaintiffs filed the action. On appeal, the Supreme Judicial Court adopted the continuing treatment exception to the discovery rule and then affirmed, holding that, because Defendant’s participation in treating the child ended more than three years before the suit was filed, the cause of action was not timely under the statute of limitations. View "Parr v. Rosenthal" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of extreme atrocity and cruelty. Defendant appealed. The Supreme Judicial Court vacated Defendant’s conviction of murder in the first degree and his sentence, holding (1) the trial court did not commit any errors that would warrant a new trial; but (2) under the circumstances of this case, a reduction of Defendant’s conviction from murder in the first degree to voluntary manslaughter was more consonant with justice. Remanded for the entry of a verdict of guilty of voluntary manslaughter and for imposition of sentence. View "Commonwealth v. Vargas" on Justia Law

The City of Springfield filed suit against the City of Papillion, and Sarpy County, seeking to enjoin Papillion from annexing land which had been indicated as Springfield’s area of future growth in a map adopted by the County in 1995. The district court for Sarpy County found that Springfield lacked standing; Springfield appealed. After review, the Nebraska Supreme Court found that Springfield asserted an infringement of its statutory governmental functions and rights under the County Industrial Sewer Construction Act. That infringement was sufficient to grant standing. The Court reversed the district court and remanded the case for further proceedings. View "Massachusetts v. Herndon" on Justia Law

Petitioners, Timothy Deal, Siegfried Golston, and Jeffrey Roberio, were juvenile homicide offenders serving mandatory indeterminate life sentences, and who had a constitutional right to a "meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation." At issue in this case was the manner in which juvenile homicide offenders were classified and placed in Department of Correction (department) facilities. Specifically, the issue was whether the department's practice of using "discretionary override codes" to block qualifying juvenile homicide offenders from placement in a minimum security facility unless and until the individual received a positive parole vote violated: (1) G. L. c. 119, section 72B (as amended by St. 2014, c. 189, section 2); or (2) their right to a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation under the Eighth and Fourteenth Amendments to the United States Constitution, arts. 12 and 26 of the Massachusetts Declaration of Rights, or both Constitutions. After review, the Supreme Court concluded that the department's current classification practice violated G. L. c. 119, section 72B, because the department's failure to consider a juvenile homicide offender's suitability for minimum security classification on a case-by-case basis amounted to a categorical bar as proscribed by the statute. Furthermore, the Court concluded that the department's practice did not violate petitioners' constitutional right to a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation because there was no constitutionally protected expectation that a juvenile homicide offender would be released to the community after serving a statutorily prescribed portion of his sentence. View "Deal v. Comm'r of Correction" on Justia Law

Plaintiff filed suit against against her employers (Defendants), alleging that she had been subject to a sexually hostile or offensive work environment. The jury rendered a verdict in favor of Plaintiff, finding that Defendants were liable for $40,000 in compensatory damages and $500,000 in punitive damages. The superior court judge granted Defendant’s motion for judgment notwithstanding the verdict in part, allowing the motion as to the award of punitive damages but denying it with respect to the award of compensatory damages. Both parties appealed. The Supreme Judicial Court affirmed the award of compensatory damages, reversed the judge’s order granting judgment notwithstanding the verdict as to the punitive damages award, and reinstated the jury’s verdict, holding that, based on the evidence, the jury could have found that Defendants failed to take adequate remedial measures after being put on notice of a sexually hostile or offensive work environment and that the failure was egregious or outrageous. Remanded for calculation of Plaintiff’s attorney’s fees and consideration of Defendant’s motion for remittitur as to the punitive damages award. View "Gyulakian v. Lexus of Watertown, Inc." on Justia Law

Plaintiff, a high school student, was suspended from school for conduct that took place outside of school grounds. The suspension - which was mistakenly ordered on the ground that Plaintiff had been charged with a felony - lasted an entire semester, and Plaintiff was unable to graduate with her class. Plaintiff commenced this action asserting that her suspension was unlawful. The judge allowed Defendants’ motion to dismiss on the ground that Plaintiff failed to exhaust her administrative remedies under Mass. Gen. Laws ch. 72, 37H1/2 before filing her complaint. The Supreme Judicial Court reversed, holding that because the tort recovery a student may seek under Mass. Gen. Laws ch. 76, 16 provides a separate and distinct remedy from that available under section 37H1/2, Plaintiff was not obligated to exhaust the statute’s administrative remedies before pursuing a tort claim under Mass. Gen. Laws ch. 76, 16. View "Goodwin v. Lee Public Schools" on Justia Law

In 2013, Defendant delivered his cellular telephone to his attorney for the purpose of seeking legal advice on several matters. In 2014, the Commonwealth filed a second motion for judicial approval of a grand jury subpoena to compel Defendant’s attorney to produce the cellular phone. The judge authorized the issuance of the subpoena, finding probable cause to believe that the telephone contained evidence of a crime under investigation by the grand jury. The Supreme Judicial Court reversed the judge’s order authorizing the issuance of a subpoena, holding that the attorney-client privilege protected Defendant against compelled production of the cellular telephone and that the protection afforded by the privilege could not be set aside based on a showing of probable cause. In 2016, the Commonwealth filed an application for an anticipatory search warrant pursuant to Mass. Gen. Laws ch. 276 1 to seize the telephone at the conclusion of a “legal advice period.” The superior court denied the application. The Supreme Judicial Court reversed, holding that a search warrant may issue for the seizure of the telephone because, absent such issuance, there is probable cause to believe that the telephone will be secreted from view. Remanded. View "Commonwealth v. Hernandez" on Justia Law