Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the first degree on a theory of extreme atrocity or cruelty and other crimes. Defendant appealed, arguing that the judge’s instruction on diminished capacity improperly limited the jury’s consideration of the evidence of his intoxication and, consequently, did not allow the jury to consider evidence of his diminished capacity from his intoxication with reference to whether the shooting was committed with extreme atrocity or cruelty. In the alternative, Defendant argued that the Supreme Judicial Court should adopt a specific intent requirement for murder committed with extreme atrocity or cruelty. The Court affirmed, holding (1) the instruction correctly conveyed to the jury that the effect upon Defendant of his intoxication was relevant to the Commonwealth’s burden to prove that Defendant acted in a cruel or atrocious manner; and (2) the instruction as given complies with current state of the law and was not erroneous. View "Commonwealth v. Boucher" on Justia Law

Petitioner was divorced from Respondent pursuant to a judgment of divorce nidi in 2014. In 2015, Petitioner filed a motion for relief from judgment. A judge of the probate and family court denied the motion. Petitioner petitioned for review. A single justice of the Appeals Court denied the petition and then denied a motion for reconsideration. The Appeals Court struck Petitioner’s notice of appeal. Thereafter, Petitioner filed a substantially similar petition in the county court pursuant to Mass. Gen. Laws ch. 211, 3. A single justice of the Supreme Judicial Court denied the petition. The Supreme Judicial Court affirmed, holding that Petitioner did not demonstrate that the denial of relief from the divorce judgment could not be addressed through the ordinary appellate process. View "Lasher v. Leslie-Lasher" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree. During the pendency of his appeal, Defendant filed a motion for a new trial, alleging that he had not been competent to stand trial. The motion judge denied the motion after a nonevidentiary hearing. The Supreme Court reversed and remanded for an evidentiary hearing. After four days of evidentiary hearings, the motion judge again denied Defendant’s motion. The Supreme Judicial Court affirmed Defendant’s conviction and the denial of his motion for a new trial and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E, holding (1) Defendant failed to establish by a preponderance of the evidence that the Commonwealth would not have been able to meet its burden at a competency proceeding had the issue been raised prior to or at trial; and (2) therefore, Defendant’s motion for a new trial was correctly denied, and, as this was the only issue raised by Defendant in his appeal, the judgment stands. View "Commonwealth v. Chatman" on Justia Law

Appellant filed a complaint against Harvard University alleging employment discrimination. The superior court granted Harvard’s motion to dismiss the complaint and denied Appellant’s subsequent attempts to reinstate the case. Appellant appealed and, while his appeal was pending, filed a motion to stay the appeal so that he could file a new complaint and seek additional discovery in the underlying action. A single justice of the Appeals Court denied the motion. The Supreme Judicial Court affirmed, holding that the single justice did not err or abuse her discretion in denying Appellant’s request for relief. View "Myrick v. Harvard University" on Justia Law

Defendant, who is not a citizen of the United States, pleaded guilty to one count of possession of cocaine. Defendant was subsequently placed in a removal proceeding. Defendant filed a motion to vacate his guilty plea, claiming that he received ineffective assistance from his plea counsel when counsel provided erroneous advice that Defendant would not be subject to deportation. The motion was denied. The Supreme Judicial Court concluded that Defendant received ineffective assistance of plea counsel and remanded the matter for additional findings relating to the issue of prejudice. On remand, the judge allowed Defendant’s motion to vacate his guilty plea and ordered a new trial. The Supreme Judicial Court affirmed, holding (1) the judge did not abuse his discretion in allowing Defendant’s motion for a new trial; and (2) the affidavits of Defendant and his plea counsel provided a sufficient basis to conclude that, but for counsel’s errors, Defendant would not have pleaded guilty and would have decided instead on going to trial. View "Commonwealth v. Sylvain" on Justia Law

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