Justia Massachusetts Supreme Court Opinion Summaries

Abinel Zenon was charged with assault and battery, among other offenses. Zenon sought certain third-party records to support his claim that the alleged victim was, in fact, the first aggressor. A judge of the district court issued a protective order concerning these records, apparently following the protocol set forth in Commonwealth v. Dwyer. Zenon subsequently filed various motions for relief from the protective order, but these motions were only partially successful. Thereafter, Zenon filed this petition for relief from a protective order. A single justice of the Supreme Judicial Court denied relief without holding a hearing after treating the petition as one filed pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court affirmed, holding that Zenon had an adequate alternative remedy. View "Zenon v. Commonwealth" on Justia Law

EventMonitor, Inc. terminated the employment of Anthony Leness, characterizing the termination as “without cause.” After discovering that Leness had copies the data on a company laptop computer EventMonitor retroactively characterized the termination as having been for cause and stopped paying Leness any severance payments. EventMonitor filed suit against Leness, alleging breach of contract, breach of the covenant of good faith and fair dealing, and breach of fiduciary duty. Leness counterclaimed for breach of contract, breach of the covenant of good faith and fair dealing, and violations of the Wage Act. A superior court judge entered judgment for Leness on EventMonitor’s claims and Leness’s counterclaims, finding that Leness had not engaged in defalcation of EventMonitor’s assets and had not committed a material breach of the employment contract, and thus that his termination could not have been for cause. The Supreme Judicial Court affirmed, holding (1) the trial judge correctly found that Leness did not commit a material breach of the employment contract and did not engage in defalcation of company assets, and therefore, Leness committed no act giving rise to a termination for cause; and (2) the trial judge correctly concluded that Leness was entitled to severance payments under the terms of the contract. View "EventMonitor, Inc. v. Leness" on Justia Law

Defendant was arraigned in the municipal court on drug-related and firearm-related charges. The court gave Defendant the bail revocation warning pursuant to Mass. Gen. Laws ch. 276, 58 and released him on personal recognizance. Defendant subsequently failed to appear at a pretrial hearing and was found to be in default. Thereafter, Defendant was charged with a new crime. At his arraignment on the new charge, the court denied the Commonwealth’s motion to revoke Defendant’s bail, concluding that he was not subject to bail revocation because he had defaulted in the prior matter, was no longer “on release,” and therefore did not commit the new crime during his period of release. The Supreme Judicial Court remanded the case with directions to vacate the lower court’s ruling for the reasons set forth in Commonwealth v. Morales, also decided today, which held that a defendant on release pursuant to Mass. Gen. Laws ch. 276, 58, who defaults for failing to appear and is subsequently charged with committing a new crime, is subject to having his bail revoked. View "Commonwealth v. Jaiman" on Justia Law

Defendant was arraigned in the district court on criminal charges in four separate matters. The court gave defendant the bail revocation warning pursuant to Mass. Gen. Laws ch. 276, 58 and released him on personal recognizance. Defendant failed to appear at a subsequent hearing and was found in default. Thereafter, Defendant was arraigned on a new charge. At his arraignment, the Commonwealth moved to revoke Defendant’s bail in the four criminal matters. The district court denied the motion, concluding that Defendant was no longer subject to bail revocation because he had defaulted in the prior matters, was thus no longer “on release,” and therefore did not commit the new crime during the period of release. The Supreme Judicial Court remanded the case with directions to vacate the lower court’s ruling for the reasons set forth in Commonwealth v. Morales, also decided today, which held that a defendant on release pursuant to Mass. Gen. Laws ch. 276, 58, who defaults for failing to appear and is subsequently charged with committing a new crime, is subject to having his bail revoked. View "Commonwealth v. Fontanez" on Justia Law

Defendant was arraigned in the municipal court on a larceny charge. The court gave defendant the bail revocation warning pursuant to Mass. Gen. Laws ch. 276, 58 and released him on personal recognizance. Defendant failed to appear at a subsequent hearing and was found in default. Defendant was subsequently charged with committing assault and battery of a family or household member. At his arraignment on the new charge, the Commonwealth moved to revoke Defendant’s bail or recognizance in the larceny matter. The municipal court judge denied the motion, concluding that Defendant was no longer subject to bail revocation because he defaulted in the prior larceny matter and, therefore, did not commit the new crime during the period of release. The Supreme Judicial Court remanded the case with directions to vacate the lower court’s ruling, holding that a defendant on release pursuant to Mass. Gen. Laws ch. 276, 58, who defaults for failing to appear and is subsequently charged with committing a new crime, is subject to having his bail revoked. View "Commonwealth v. Morales" on Justia Law

Defendant was investigated for, but not indicted for, a 1974 murder. More than twenty-five years later, DNA analysis of tissue taken from under the fingernails of the victim led to Defendant’s indictment for the murder. In 2012, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. Just before Defendant filed his appellate brief with the Supreme Judicial Court, he filed a motion to stay the execution of his sentence. A single justice of the Supreme Judicial Court denied the motion. The Supreme Judicial Court affirmed, holding (1) the trial court erred in denying Defendant’s motion to suppress evidence of a paper towel that the police seized from Defendant’s vehicle, but the error was harmless beyond a reasonable doubt; (2) the trial judge did not err in denying Defendant’s pretrial motion to dismiss the murder indictment on the ground that the Commonwealth recklessly or negligently delayed indicting him for thirty-two years, as Defendant failed to show that he was prejudiced by the preindictment delay; (3) Defendant was not entitled to relief under Mass. Gen. Laws ch. 278, 33E; and (4) the single justice did not abuse his discretion in denying Defendant’s motion to stay execution of sentence. View "Commonwealth v. Dame" on Justia Law

Joshua Charbonneau was charged with larceny over $250. The Holyoke District Court issued an amended standing order on March 31, 2015 providing that a defendant was to tender a defendant-capped plea no later than 2 p.m. the day before trial. Because Charbonneau’s trial was scheduled to occur after the effective date of the standing order, his option to tender a defendant-capped plea at trial was foreclosed. Charbonneau petitioned for relief pursuant to Mass. Gen. Laws ch. 211, 3, claiming an inviolable statutory right to tender a defendant-capped plea on the day of trial. The Supreme Judicial Court vacated the standing order insofar as it purported to preclude the tender of a defendant-capped plea on the day of trial, holding that the standing order conflicted with and impaired a defendant’s right to tender a defendant-capped plea as provided in Mass. Gen. Laws ch. 278, 18 and Mass. R. Crim. P. 12. View "Charbonneau v. Holyoke Div. of Dist. Court Dep’t" on Justia Law

Police officers applied for and obtained a warrant to search Defendant’s iPhone. The warrant authorized a search of Defendant’s iPhone for evidence of communications that would link him and another suspect to a shooting. The search resulted in the discovery and seizure of photographs of Defendant holding a gun. Defendant was subsequently charged with possession of a firearm without a license and related offenses. Defendant moved to suppress the photographs obtained from the search of his iPhone. The motion judge denied the motion to suppress, concluding that it was appropriate for the police to search the files on Defendant’s phone that contained his photographs. The Supreme Judicial Court affirmed, holding (1) because communications relating to and linking Defendant to the crimes under investigation would be found in photograph form on Defendant’s iPhone, a search of the photograph files was reasonable; and (2) the photographs at issue were properly seized as evidence linking Defendant to the crimes under investigation. View "Commonwealth v. Dorelas" on Justia Law

Defendant was on parole when his parole officer and others searched his apartment without a warrant and seized cocaine from his bedroom door. Defendant was indicted for possession of cocaine with intent to distribute. Defendant filed a motion to suppress the evidence seized from his home, arguing that the search was unconstitutional under both the United States and Massachusetts Constitutions. The motion judge allowed Defendant’s motion to suppress, holding that the search did not violate the Fourth Amendment but did violate article 14 of the Massachusetts Declaration of Rights. Specifically, the judge concluded that article 14 offers the same protections for parolees as it does for probations and that searches of a parolee’s residence must be supported by both reasonable suspicion and either a search warrant or a traditional exception to the search warrant. The Supreme Judicial Court vacated the allowance of Defendant’s motion to suppress, holding (1) article 14 does not offer as much protection to parolees as it affords to probationers, and therefore, reasonable suspicion is sufficient to justify a warrantless search of the parolee’s home; and (2) the officer in this case had reasonable suspicion that a search of Defendant’s home would produce evidence of a parole violation. View "Commonwealth v. Moore" on Justia Law

After a fire broke out at the Beacon Towers Condominium, the board of trustees for the Beacon Towers Condominium Trust, the unit owners’ organization for the condominium, assessed George Alex $62,995 for the two units that he owned. Alex commenced an arbitration action challenging the propriety of the trustees’ conduct regarding the fire damage repairs and the imposition of the assessment. The arbitration panel found in favor of Alex. Although the panel recognized that the arbitration agreement in the trust’s bylaw did not provide for an award of fees, the panel nonetheless awarded fees, reasoning that the American Arbitration Association allowed an award of fees where “substantially all of the defenses were wholly insubstantial, frivolous and not advanced in good faith.” The trust filed suit, claiming that the arbitrators’ award of attorney’s fees exceeded the scope of the parties’ arbitration agreement. A superior court judge vacated the award of attorney’s fees, concluding that such an award was not authorized by Mass. Gen. Laws ch. 231, 6F when ordered by an arbitrator because section 6F does not authorize an arbitrator to award attorney’s fees. The Supreme Judicial Court affirmed, holding that an arbitrator lacks the authority to award attorney’s fees under the circumstances of this case. View "Beacon Towers Condo. Trust v. Alex" on Justia Law