Justia Massachusetts Supreme Court Opinion Summaries

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

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