Justia Massachusetts Supreme Court Opinion Summaries

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

This matter stemmed between a billing dispute between Petitioner, an attorney, and Respondent, the Committee for Public Counsel Services. Certain administrative proceedings culminated in a hearing, and the hearing officer rendered a decision adverse to Petitioner. Thereafter, Petitioner filed two separate complaints, one in the nature of certiorari and one for a declaratory judgment. The trial judge denied the motion on the certiorari action but allowed the motion in the declaratory judgment action. Respondent later moved to dismiss the certiorari action for failure to prosecute. The trial court allowed the motion. Petitioner then filed papers in the county court entitled “writ of mandamus” and “writ of certiorari,” which a single justice treated as a petition pursuant to Mass. Gen. Laws ch. 211, 3. The single justice denied relief. The Supreme Judicial Court affirmed, holding that the single justice did not err or abuse his discretion in denying relief. View "Schubert v. Comm. for Pub. Counsel Servs." on Justia Law

Defendant admitted to facts sufficient to warrant a finding of guilty to stealing the property of Walmart having a value of more than $250 pursuant to a single larcenous scheme. At a restitution hearing, the judge declared that Walmart’s loss was measured by the retail loss and ordered that Defendant pay $5,256 in restitution. The Supreme Judicial Court vacated the judge’s restitution order, holding (1) in determining whether to impose restitution and the amount of restitution, a judge must consider a defendant’s ability to pay, and in this case, the judge erred in failing to consider Defendant’s ability to pay in determining whether to order restitution and in determining the amount of restitution; and (2) in cases of retail theft, the amount of actual economic loss for purposes of restitution is the replacement value of the stolen goods unless the Commonwealth proves that the stolen goods would otherwise have been sold, in which case the retail sales value is the measure of actual loss, and in this case, the judge did not err in determining that the appropriate amount of Walmart’s actual loss was the aggregate retail price of the items stolen. Remanded. View "Commonwealth v. Henry" on Justia Law

As part of a judgment of divorce, the probate and family court judge awarded Wife sixty percent of Husband’s interest in the present value of a discretionary spendthrift trust. Husband appealed, arguing that the judge abused her discretion by including the trust in the marital estate. The Appeals Court affirmed. The Supreme Judicial Court vacated the order dividing Husband’s interest in the trust, holding that Husband’s interest in the trust was so speculative as to constitute nothing more than an expectancy, and therefore, it was not assignable to the marital estate. Remanded. View "Pfannenstiehl v. Pfannenstiehl" on Justia Law

Plaintiffs filed an action to quiet title, alleging that a railroad easement formerly owned by the Pennsylvania Central Transportation Co. across portions of their lands was abandoned by the United States Railway Association by virtue of its non designation for transfer to the Consolidated Rail Corporation in a final plan system. The land court dismissed without prejudice Plaintiffs’ action for lack of subject matter jurisdiction, concluding that a certificate of abandonment from the Federal Surface Transportation Board (STB) was necessary before a state court could exercise jurisdiction to determine state law claims regarding easements and that STB’s jurisdiction was exclusive and primary. The Supreme Judicial Court affirmed, holding that the land court did not err in determining that the question of abandonment in this case remained in the exclusive jurisdiction of the federal government and, therefore, the land court did not have subject matter jurisdiction over Plaintiffs’ action. View "Murray v. Dep’t of Conservation & Recreation" on Justia Law

In a probation surrender proceeding based on the use of marijuana, purportedly for medical purposes, the judge found Defendant in violation of probation for the use of marijuana, terminated his probation, and imposed a prison sentence. Defendant, who was a qualifying patient under the medical marijuana law (act), appealed, arguing (1) his sentence violated his right to the medical use of marijuana without adverse legal consequences, and (2) counsel provided ineffective assistance by failing to assert the immunity provision of the act. The Supreme Judicial Court affirmed, holding (1) under the circumstances of this case, the judge did not err in finding Defendant in violation of his probation; and (2) there was no prejudice in counsel’s stipulating to the violation without raising the issue as a defense to the violation. View "Commonwealth v. Vargas" on Justia Law

District court judges ordered the two defendants in these consolidated cases to pretrial detention under the dangerousness statute, Mass. Gen. Laws ch. 276, 58A, under which a person “held under arrest” on charges of one of an enumerated list of offenses may be subject to a pretrial detention hearing. Defendants both argued that they were not “held under arrest” within the meaning of the statute when they appeared in court to be arraigned and, therefore, could not lawfully be subjected to a pretrial detention hearing. The Supreme Judicial Court affirmed the orders of pretrial detention, holding that where a criminal defendant has been arrested or is subject to an outstanding arrest warrant for an enumerated offense, he or she may be subject to pretrial detention under the dangerousness statute, even if the defendant is not held in custody following the arrest, so long as the dangerousness hearing takes place immediately upon the defendant’s first appearance before the court. View "Commonwealth v. Diggs" on Justia Law

Plaintiffs lost electric power during a major winter ice storm in 2008. Plaintiffs sued Fitchburg Gas and Electric Light Company (FG&E) and sought class certification for themselves and other residential and business customers of FG&E who were injured by FG&E’s allegedly inadequate preparation for and response to the storm. The superior court judge denied Plaintiffs’ motion for class certification. The Supreme Judicial Court affirmed the denial of class certification, concluding that the asserted injuries suffered by the class members were too dissimilar. Plaintiffs then filed a renewed motion for class certification premised on an alternate theory of injury. Specifically, Plaintiffs contended that they suffered economic injury by overpaying for a level of emergency preparedness that FG&E deceptively failed to provide. The superior court judge certified two classes of FG&E customers and reported the class certification order. The Supreme Judicial Court vacated the order certifying the class, holding that, under the circumstances, Plaintiffs’ assertion of overpayment for FG&E’s services did not set forth a cognizable injury under Mass. Gen. Laws ch. 93A, 9(1) and 11 and therefore did not support class certification pursuant to the statute. View "Bellermann v. Fitchburg Gas & Elec. Light Co." on Justia Law

After a jury trial in 1997, Petitioner was convicted of murder in the first degree on a theory of felony murder. Petitioner later filed a motion in the superior court seeking postconviction testing of biological material pursuant to Mass. Gen. Laws ch. 278A, 3. The superior court judge denied Petitioner’s motion for scientific testing. Petitioner then filed a petition seeking leave to appeal from the denial of his motion for forensic and scientific testing. The Supreme Judicial Court reversed, holding that Petitioner demonstrated that the requested analysis had not yet been developed at the time of his conviction and therefore met the requirement to establish one of the five enumerated reasons explaining why the requested testing was not previously conducted, and therefore, the trial judge erred in denying Petitioner’s motion. View "Commonwealth v. Wade" on Justia Law