Justia Massachusetts Supreme Court Opinion Summaries

Plaintiffs in this putative class action were inmates serving criminal sentences in various Massachusetts prison facilities who had, for varying lengths of time, been placed in a special management unit (SMU) in nondisciplinary administrative segregation. Plaintiffs brought this action alleging that their placements in the SMUs violated their constitutional rights to due process, as well as regulations of the Department of Correction. Plaintiffs sought to represent a class of similarly situated prisoners confined in SMUs. A judge denied Plaintiffs’ motion for class certification and, relying on the Supreme Judicial Court’s decision in LaChance v. Commissioner of Correction, dismissed Plaintiffs’ complaint. The Appeals Court dismissed Plaintiffs’ appeal as moot, as, by then, no named plaintiffs remained in SMUs. The Supreme Judicial Court reversed, holding (1) in light of the class action allegations in Plaintiffs’ complaint, the appeal was not moot; and (2) LaChance did not resolve the merits of all of Plaintiffs’ claims. Remanded. View "Cantell v. Commissioner of Correction" on Justia Law

After a jury trial, Defendant was convicted of one count of rape of a child. The underlying indictment alleged that Defendant raped his daughter on diverse dates between 1979 and 1981. Defendant appealed, raising statute of limitations claims. The Supreme Judicial Court vacated Defendant’s conviction, holding (1) the Commonwealth presented sufficient evidence from which the jury could determine that the indictment was timely returned, but the jury instruction concerning how to make this determination was incorrect, which resulted in a substantial risk of a miscarriage of justice; (2) the required independent corroboration of any incidents of rape that occurred more than twenty-seven years before the indictment was returned must relate to the specific criminal act or acts of which a defendant is accused, and evidence of uncharged misconduct does not suffice; and (3) the Commonwealth’s corroborative evidence consisting only of evidence of uncharged misconduct was insufficient as a matter of law. Remanded for a new trial. View "Commonwealth v. White" on Justia Law

Defendant was convicted as a joint venturer of murder in the first degree, armed robbery, and assault and battery by means of a dangerous weapon. The Supreme Judicial Court affirmed the convictions and discerned to reason to exercise its authority to grant extraordinary relief, holding (1) the trial court did not err in denying Defendant’s motions for required findings of not guilty, as the evidence was sufficient to support the convictions; (2) the trial court did not err in denying Defendant’s motion to dismiss on speedy trial grounds, as Defendant acquiesced to an additional period of delay; and (3) certain evidence, including Defendant’s oral statements to police, was properly admitted at trial. View "Commonwealth v. Williams" on Justia Law

After a jury trial, Defendant was found guilty of possession with intent to distribute heroin and possession with intent to distribute cocaine. Defendant pleaded guilty to the subsequent offense portion of each of these charges. After a hearing, the trial judge stated that she would depart downward from the mandatory minimum sentence provisions of the two subsequent offense statutes. The Commonwealth filed a petition for relief pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Court allowed the Commonwealth’s petition for relief and vacated Defendant’s sentences, holding that because the Legislature has not yet enacted into law sentencing guidelines recommended by the Massachusetts Sentencing Commission, Mass. Gen. Laws ch. 211E, 3(e) does not authorize a sentencing judge to depart from the mandatory minimum terms specified by statute for subsequent drug offenses. View "Commonwealth v. Laltaprasad" on Justia Law

Defendant owned and managed a nature preserve on Martha’s Vineyard compromised of parcels of land owned by Defendant. In 2010, Defendant created a hiking trail through the preserve that crossed over Plaintiffs’ property via an easement. The trail proceeded across three parcels of Defendant’s land for whose benefit the easement was created and then entered a fourth parcel owned by Defendant that was not intended to benefit from the easement. Plaintiffs filed an action to prevent Defendant from using the easement as part of the hiking trial, arguing that the bright-line rule in Murphy v. Mart Realty of Brockton, Inc. disallows any use of an easement to benefit land to which the easement is not appurtenant. On that basis, a land court judge granted partial summary judgment in favor of Plaintiffs. Defendant appealed, arguing that the bright-line rule in Murphy is overly rigid and suggested, instead, that the Court adopt a fact-intensive inquiry considering whether the use of an easement to benefit other parcels would increase unfairly the burden on the easement. The Supreme Judicial Court affirmed and thus declined to adopt Defendant’s suggestion, holding that the benefits of preserving the bright-line rule set forth in Murphy outweigh any costs associated with its rigidity. View "Taylor v. Martha's Vineyard Land Bank Comm’n" on Justia Law

Plaintiff sued her employer for sex discrimination, race discrimination, and retaliation under Mass. Gen. Laws ch. 151B, 9. The jury found in favor of Plaintiff on her retaliation claim and awarded her both compensatory and punitive damages. Defendant was additionally ordered to pay attorney’s fees and costs. The judgment did not provide for postjudgment interest on punitive damages, costs, and attorney’s fees. Plaintiff appealed, arguing that her request for postjudgment interest should have been granted. The Supreme Judicial Court affirmed the judgment, holding that the trial judge correctly denied Plaintiff’s request for postjudgment interest on the award of punitive damages, costs, and attorney’s fees because Mass. Gen. Laws ch. 151B, 9 does not contain language that necessarily implies that the Commonwealth should be liable for such postjudgment interest. View "Brown v. Office of Comm’r of Probation" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and assault and battery with a dangerous weapon. The Supreme Judicial Court reversed the convictions and remanded the case for a new trial due to errors in Defendant’s first trial. On remand, Defendant was convicted of murder in the first degree by extreme atrocity or cruelty and assault and battery by means of a dangerous weapon. Defendant was sentenced to life in prison without the possibility of parole on the murder conviction. The Supreme Judicial Court affirmed on appeal, holding (1) the Commonwealth made improper statements during closing arguments, but this error did not warrant a new trial or other relief; (2) Defendant’s remaining allegations of error were unavailing; and (3) the Court discerns no basis to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Durand" on Justia Law

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