Justia Massachusetts Supreme Court Opinion Summaries

Petitioner pleaded guilty in a Connecticut court to a sex crime. As conditions of his probation, Petitioner was ordered not to leave Connecticut and to submit to electronic monitoring. Petitioner’s supervision was later transferred to Massachusetts, and a Connecticut judge ordered GPS monitoring be at the discretion of the Massachusetts Department of Probation. Thereafter, Petitioner requested that he not be subjected to mandatory GPS monitoring and that he be considered for travel permits to certain states. The Massachusetts Commissioner of Probation largely denied the request. After Petitioner was found in violation of probation conditions by a Connecticut judge, Petitioner filed a petition in the pursuant to Mass. Gen. Laws ch. 211, 3 seeking relief from the orders of the Commissioner. The Supreme Judicial Court held (1) where a petitioner argues that a special condition of probation that was added by Massachusetts is not mandated by Massachusetts law or is unconstitutional, this determination should be made by a Massachusetts court through a complaint for declaratory relief; (2) the Massachusetts may not add mandatory GPS monitoring as a special condition of probation for Petitioner; and (3) the prohibition on out-of-state travel for probationers being supervised for sex offenses is not an additional condition of probation imposed on a transferred probationer. View "Goe v. Comm’r of Probation" on Justia Law

After a jury trial, Defendant was found guilty of attempted armed robbery and murder in the first degree on theories of extreme atrocity or cruelty and felony murder. Defendant was sentenced to life imprisonment on the murder charge. Defendant appealed, challenging the admission into evidence of his videotaped statement to the police and a statement he made while he was left alone during the police interrogation. Specifically, Defendant argued that although he initially waived his Miranda rights, he later invoked his right to remain silent and that the police did not scrupulously honor this invocation. Defendant failed to raise this claim below. The Supreme Judicial Court reversed Defendant’s convictions, holding that the police’s failure to honor Defendant’s right to terminate questioning created a substantial likelihood of a miscarriage of justice because the statement was likely to have affected the jury’s verdict. View "Commonwealth v. Smith" on Justia Law

Plaintiffs and Defendant, members of an accounting firm (Firm), were parties to a stockholder agreement (Agreement) that contained an arbitration clause. The parties’ agreement to arbitrate was governed by the Massachusetts Uniform Arbitration Act for Commercial Disputes. When Plaintiffs voted to require the withdrawal of Defendant as a director and stockholder in the Firm, Defendant opened his own accounting firm. The nature and terms of Defendant’s withdrawal from the Firm and his subsequent competition with the Firm were the bases of a dispute between the parties. The dispute was submitted to binding arbitration. The arbitrator issued a final award awarding the Firm $1.7 million plus interest. The superior court confirmed the arbitration award. Defendant appealed, arguing (1) the arbitrator fundamentally misinterpreted the agreement, and (2) he was entitled to have a court consider the merits of his claim because, in the arbitration clause of the agreement, the parties specifically provided for judicial review of an award to determine if there was flagrant error by the arbitrator. The Supreme Judicial Court affirmed the motion judge’s confirmation award, holding (1) the grounds of judicial review in this case were limited to those delineated in Mass. Gen. Laws ch. 215, 12 and 13; and (2) Defendant’s claim was not reviewable by the Court. View "Katz, Nannis & Solomon, P.C. v. Levine" on Justia Law

Plaintiff filed an eight-count complaint against her former employer (Hospital) and former supervisor (collectively, Defendants). One count of Plaintiff’s complaint survived for purposes of trial. The jury returned a verdict finding that the Hospital terminated Plaintiff’s employment in retaliation for her exercise of the right to take medical leave under the Federal Family and Medical Leave Act (FMLA). The jury awarded Plaintiff damages in the form of back pay and front pay. Defendants filed a motion for judgment notwithstanding the verdict (j.n.o.v.) or, in the alternative, for a new trial. The trial judge allowed the motion for j.n.o.v. and ruled that there was insufficient evidence to provide for an award of front pay. The Supreme Judicial Court reversed the allowance of Defendant’s motion for j.n.o.v. and affirmed the judge’s order with respect to front pay, holding (1) the evidence was sufficient to permit a jury to conclude that Defendants retaliated against Plaintiff because she exercised her right to FMLA leave; and (2) the trial judge did not err in determining that the evidence at trial was insufficient to support an award of front pay. Remanded for further proceedings with respect to Defendants’ alternative request for a new trial. View "Esler v. Sylvia-Reardon" on Justia Law

Defendant was charged with attempted murder and related assault and battery and child endangerment crimes for not giving prescribed chemotherapy and other medications designed to treat the cancer from which her son ultimately died. The Supreme Judicial Court affirmed Defendant’s conviction of reckless child endangerment but reversed the judgments on the assault and battery charges and the order denying Defendant’s motion for a new trial on the charge of attempted murder, holding (1) the judge’s instructions correctly explained the elements of attempted murder, and nonachievement of murder is not an element of attempted murder; (2) the trial evidence was insufficient to permit convictions of the two assault and battery charges, and the judge’s instructions were legally incorrect; and (3) the judge erred in denying Defendant’s motion for a new trial on the ground of ineffective assistance of counsel. Remanded. View "Commonwealth v. LaBrie" on Justia Law

Employee was severely injured while traveling abroad on a business trip. Employer had purchased two workers’ compensation policies from two different insurers, the Insurance Company of the State of Pennsylvania (ISOP) and Great Northern Insurance Company (Great Northern). Both policies provided primary coverage. Employee pursued a workers’ compensation claim. Employer gave notice of the claim only to ISOP. ISOP began making payments pursuant to the policy and defended the claim. When ISOP learned that Employer also had workers’ compensation coverage under its Great Northern policy, ISOP filed a complaint against Great Northern seeking a judgment declaring that the doctrine of equitable contribution required Great Northern to pay one-half of the past and future defense costs and indemnity payments related to Employer’s claim. A federal district court granted summary judgment for Great Northern. ISOP appealed, and the United States Court of Appeals for the First Circuit certified a question to the Supreme Court. The Court answered that, where two primary workers’ compensation insurance policies provide coverage for the same loss arising from an injury to an employee, the insurance company that pays that loss has a right of equitable contribution from the coinsurer, regardless of whether the insured gives notice of the injury only to one insurer. View "Ins. Co. of State of Penn. v. Great N. Ins. Co." on Justia Law

When Plaintiff retired in 2004 from his position as a sergeant with the Cambridge police department, he was issued a retired officer identification card that had no expiration date. In 2011, Plaintiff applied for the issuance of a replacement ID card because his had broken. The police commissioner of the city of Cambridge denied the application on the grounds that Defendant “ha[d] not met the standard set by the Department.” Plaintiff sued for declaratory and injunctive relief. The trial judge granted summary judgment for Plaintiff, determining that he was entitled to receive a replacement ID card because he had retired “in good standing.” The Supreme Judicial Court affirmed, but for reasons different from those articulated by the judge, holding (1) the commissioner abused his discretion in finding that Plaintiff had not met the standard set by the Department, and (2) therefore, Plaintiff was entitled to receive a replacement ID card. View "Frawley v. Police Comm’r of Cambridge" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. Defendant subsequently filed a motion for a new trial based on alleged trial errors. The motion was denied after an evidentiary hearing. The Supreme Judicial Court affirmed the order denying Defendant’s motion for new trial as well as Defendant’s conviction and discerned no basis to exercise its authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court erroneously admitted certain DNA evidence, but there was no substantial likelihood of a miscarriage of justice; (2) trial counsel was not ineffective for introducing audiotapes of prior consistent statements made by the Commonwealth’s principal witness for impeachment purposes; (3) there was no substantial likelihood of a miscarriage of justice created by the admission of a cooperating codefendant’s plea agreement without prior redaction; (4) there was no error in the admission of prior bad act evidence; and (5) trial counsel did not provide ineffective assistance. View "Commonwealth v. Lally" on Justia Law

After Petitioner’s condominium unit was foreclosed upon, Respondent became the new owner. Respondent commenced a summary process action against Petitioner, and the court ruled in Respondent’s favor. The Appellate Division affirmed. Petitioner then filed a petition for relief pursuant to Mass. Gen. Laws ch. 211, 3, arguing that the attorneys who represented her in the foreclosure proceedings committed fraud, and therefore, the judgment against her in the summary process action was void because the underlying foreclosure was void. A single justice of the Supreme Judicial Court denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that the single justice properly denied relief where Petitioner failed to demonstrate the absence or inadequacy of other remedies. View "Kim v. Rosenthal" on Justia Law

Plaintiff, a black male of African descent who had a medical degree from the University of the West Indies, was terminated from his employment with Mount Auburn Hospital while completing the first year of his residency. Plaintiff filed a ten-count complaint against the Hospital and three physicians who supervised his work, asserting employment discrimination and breach of contract, among other claims. The Appeals Court reversed as to the discrimination and breach of contract claims. The Supreme Judicial Court vacated the judgments in favor of Defendants on Plaintiff’s claims for employment discrimination and breach of contract, holding that Defendants were not entitled to summary judgment and that Plaintiff presented sufficient evidence to allow a jury to hear his claims. View "Bulwer v. Mount Auburn Hospital" on Justia Law