Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendants Branden Mattier and Domunique Grice were convicted on indictments charging one count each of conspiracy to commit larceny and attempted larceny. Mattier was also convicted on an indictment charging one count of identity fraud. The convictions arose from Defendants’ attempt to defraud The One Fund Boston by claiming that a long-deceased aunt had been injured in the 2013 bombing of the Boston Marathon. The Supreme Judicial Court vacated in part and affirmed in part, holding (1) Mattier’s identity fraud conviction failed as a matter of law, but Defendants’ remaining convictions were based on sufficient legally obtained evidence; (2) the trial judge did not err in denying the motion to suppress evidence obtained as a result of Mattier’s warrantless arrest for the identity fraud and attempted larceny charges; (3) the trial judge did not err in denying the motion to strike for cause jurors who donated to One Fund; and (4) the prosecutor’s statements during closing arguments did not require reversal. View "Commonwealth v. Mattier" on Justia Law

Appellant was convicted of murder in the second degree and other offenses. The Supreme Judicial Court affirmed on appeal. Thereafter, Appellant filed a motion for relief from unlawful restraint pursuant to Mass. R. Crim. P. 30(a). The superior court denied the motion. Appellant sought direct appellate review. At issue before the Supreme Judicial Court was whether, on direct appeal, the Court properly applied Commonwealth v. Zanetti to determine that the evidence was sufficient to support Appellant’s convictions. The Supreme Court affirmed the order denying Appellant’s motion for relief from unlawful restraint, holding that the evidence presented at trial was sufficient to convict Appellant, and the application of Zanetti to Appellant’s case did not violate ex post facto principles or Appellant's due process rights. View "Commonwealth v. Miranda" on Justia Law

Justice Ainooson commenced an action in the superior court against several individual defendants. After an extension of time to effect service was allowed, Ainooson moved to waive service or to deem the defendants served. The judge allowed the motion but then vacated her allowance after the defendants filed a motion for reconsideration. A different judge then ordered Ainooson to make service by regular mail at his own expense with no further extensions allowed. Ainooson filed a Mass. Gen. Laws ch. 211, 3 petition challenging the rulings. Before the single justice ruled on the petition, the superior court dismissed the complaint. The single justice denied extraordinary relief. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused his discretion in denying extraordinary relief. View "Ainooson v. Dep’t of Corr." on Justia Law

After a jury trial, Defendant was convicted on thirty indictments, ten each charging armed robbery while masked, home invasion, and kidnapping. The Appeals Court affirmed. Defendant appealed, arguing that the trial judge erred in failing to instruct the jury regarding eyewitness identification in accordance with Commonwealth v. Rodriguez. Defendant, however, neither requested the instruction nor objected to its admission. In the alternative, Defendant claimed that counsel’s failure to request a Rodriguez instruction was constitutionally ineffective. The Supreme Judicial Court affirmed, holding (1) in the absence of a request, Defendant may not attribute the omission of a Rodriguez eyewitness identification instruction to judicial error and, consequently, Defendant was not entitled to review on that ground; and (2) counsel’s failure to request a Rodriguez instruction in this case was error, but the error was not prejudicial. View "Commonwealth v. Navarro" on Justia Law

At issue in this case was whether a parent whose minor child is the subject of a guardianship petition has a right to counsel when and if the parent petitions to have the guardian removed or to have the terms of the guardianship modified. Plaintiffs, the mothers of minor children for whom guardians were appointed pursuant to Mass. Gen. Laws ch. 190B, 5-206, commenced this action challenging a written policy of the Chief Justice of the Probate and Family Court Department concerning the appointment of counsel in cases involving guardianships of minors under chapter 190B. Specifically, Plaintiffs alleged that by limiting the right to counsel to proceedings for the initial appointment of guardians, the Chief Justice’s policy contravened the Supreme Judicial Court’s decision in Guardianship of V.V. and violated their due process rights. The Supreme Judicial Court held that an indigent parent who seeks to remove a guardian for a minor child and to regain custody of the child or seeks to modify the terms of a guardianship by substantially changing the terms of visitation with a minor child has a due process right to counsel and to be so informed, provided that the parent presents a meritorious claim for removal or modification. View "L.B. v. Chief Justice of Probate & Family Court Dep’t" on Justia Law

After a jury trial, Defendant was convicted on three indictments charging conspiracy, attempted larceny, and identity fraud. Defendant appealed his convictions and filed a motion for stay of the execution of his sentence pending appeal. The trial judge denied the motion. Defendant appealed and filed a motion for stay of the execution of the sentence in the Appeals Court. The Supreme Judicial Court granted Defendant’s application for direct appellate review of his appeal. Thereafter, Defendant filed a motion for stay in the Supreme Judicial Court. A single justice denied the motion. Defendant appealed and filed a motion for an expedited ruling. The Supreme Judicial Court affirmed, holding that the single justice did not err in finding that the trial judge did not abuse his discretion in denying Defendant’s motion for stay. View "Commonwealth v. Mattier" on Justia Law

The decedent in this case was killed in a one-car accident when he drove in an intoxicated state after leaving a restaurant owned by Defendants. Plaintiff filed a complaint under the Commonwealth’s wrongful death statute, alleging that Defendants exhibited negligent, willful, wanton, and reckless conduct by selling and serving alcoholic beverages to the decedent prior to the decedent’s fatal motor vehicle accident and that such conduct was the proximate cause of the decedent’s death. Plaintiff submitted an affidavit pursuant to Mass. Gen. Laws ch. 231, 60J (commonly referred to as the dram shop act) stating that it was based on information and belief gathered from witness statements, a police report, and a medical toxicology report. Defendants moved to strike the affidavit and for partial summary judgment of Plaintiff’s complaint, arguing that a section 60J affidavit must be based upon personal knowledge. The superior court denied Defendants’ motion. The Supreme Judicial Court affirmed, holding (1) a section 60J affidavit based on information and belief may be sufficient to satisfy the procedural requirements of the statute; and (2) in this case, the affidavit satisfied the requirements of section 60J. View "Bayless v. TTS Trio Corp." on Justia Law

Landlord brought a summary process action against Tenant for possession of the premises. Tenant counterclaimed, alleging violations of the security deposit statute and other causes of action. The Housing Court found in favor of Landlord on all but the security deposit claim, ruling that Tenant could properly assert a violation of the security deposit statute as a counterclaim for damages but that a counterclaim on this basis was not a defense to Landlord’s claim for possession. The Supreme Judicial Court reversed the Housing Court judgment granting possession to Landlord, holding that a counterclaim or defense on the basis of a violation of the security deposit statute may be asserted as a defense to a landlord’s possession in a summary process action under Mass. Gen. Laws ch. 239, 1A. View "Meikle v. Nurse" on Justia Law

DiMasi, a former Speaker of the Massachusetts House of Representatives, resigned from his position in 2009 and began receiving retirement benefits from the State Board of Retirement (board). A federal grand jury subsequently indicted DiMasi for violating several federal laws while in office. Consequently, the board voted to suspend DiMasi’s retirement allowance. DiMasi sought judicial review, and the municipal court entered summary judgment in favor of DiMasi. The board appealed. Thereafter, a federal jury found DiMasi guilty of seven counts of the superseding indictment. On September 9, 2011, DiMasi was sentenced to a term of imprisonment. The board again voted to suspend payment of DiMasi’s retirement allowance. A hearing officer concluded that DiMasi’s convictions became “final” for purposes of Mass. Gen. Laws ch. 32, 15(4) when he was sentenced, and therefore, DiMasi forfeited his retirement allowance as of September 9, 2011. On January 14, 2014, all of DiMasi’s direct appeals were exhausted. The municipal court agreed with the board that the term “final” meant the date when DiMasi was sentenced and not the date when all of his direct appeals were exhausted. The Supreme Judicial Court affirmed, holding that in the context of pension forfeiture, a “final conviction” occurs when an individual is sentenced and not at the conclusion of the appellate process. View "DiMasi v. State Bd. of Retirement" on Justia Law

In the late 1990s, Robert James, acting on behalf of the Robert and Ardis James Foundation, agreed to advance more than $650,000 to Daniel Meyers to purchase shares of stock in a fledgling, privately held company that Meyers had cofounded in exchange for a portion of the proceeds of an eventual sale of those shares. The agreement did not discuss the timing of sale. Beginning in 2004, the foundation sought to bring the agreements to a close, but Meyers did not comply. In 2006, the foundation filed a complaint against Meyers seeking specific performance and damages. The superior court concluded that Meyers had committed a breach of the implied covenant of good faith and fair dealing and awarded damages based on a date of breach of July 31, 2006. The Supreme Judicial Court affirmed, holding that the trial court correctly found that Meyers committed a breach of the implied covenant and did not err in setting the date of breach at July 31, 2006. View "Robert & Ardis James Found. v. Meyers" on Justia Law