Justia Massachusetts Supreme Court Opinion Summaries

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

Defendant was charged with reckless endangerment of a child by walking on railroad tracks with a child. The trial judge dismissed the count of reckless endangerment, concluding (1) the Commonwealth was required to establish that Defendant was actually aware of the substantial risk of serious bodily injury to which he exposed his child, and (2) sufficient evidence was not presented in the application for the criminal complaint to establish probable cause to believe Defendant had the requisite mental state. The Supreme Court vacated the order of dismissal, holding (1) the trial judge correctly stated the law; and (2) the probable cause requirement was satisfied in this case. View "Commonwealth v. Coggeshall" on Justia Law

Defendant was convicted of armed robbery while masked, kidnapping for purposes of extortion, and armed assault with intent to murder. The Appeals Court affirmed the convictions. Defendant appealed, arguing that the trial court erred in denying his motion to suppress his cellular telephone records. Specifically, Defendant contended that the government failed to comply with Mass. Gen. Laws ch. 271, 17B, as then in effect, in obtaining his telephone records. The Supreme Judicial Court affirmed, holding that Mass. Gen. Laws ch. 271, 17B, as then in effect, did not preclude the government from obtaining the records at issue in this case, and therefore, Defendant’s motion to suppress the records was correctly denied. View "Commonwealth v. Chamberlin" on Justia Law

These cases were appeals of consolidated care and protection petitions concerning six children. The biological mother of the six children, the biological father of the two oldest children, and four of the children appealed from the provisions of decrees of the juvenile court denying parental visitation after termination of the parental rights of the mother, father, and the biological father of the four younger children. The Supreme Judicial Court affirmed the juvenile court judge’s orders denying posttermination or postadoption parental visitation, holding that there was no error in the judge’s decrees in this case. View "In re Adoption of Douglas" on Justia Law

Appellant pleaded guilty to several crimes in connection with an arrest for attempted burglary and other offenses. Appellant moved to vacate two of his convictions of attempted armed burglary and his conviction of possessing a burglarious tool or implement pursuant to Mass. R. Crim. P. 30(a), asserting (1) the convictions of attempted burglary were duplicative, and (2) his conviction for possessing a burglarious instrument should be vacated because the indictment failed to state a crime. The superior court judge denied the motion. The Supreme Judicial Court affirmed in part and reversed in part the denial of Appellant’s motion for postconviction relief, holding (1) Appellant’s multiple convictions and punishments for attempted armed burglary were for separate attempts, and therefore, his multiple convictions and punishments did not violate double jeopardy; but (2) the indictment charging possession of a burglarious tool or implement failed to allege a crime, and therefore, Appellant’s conviction must be vacated. View "Commonwealth v. Dykens" on Justia Law

Two employees were injured in the course of their employment, collected workers’ compensation benefits and then reached settlement agreements with third parties including damages for their pain and suffering. The same insurer insured by employers and sought reimbursement from the employees’ recoveries. In one employee’s case, the superior court judge rejected a settlement agreement providing that the insurer would not have a lien on the damages for pain and suffering. In the second employee’s case, a superior court judge approved a settlement agreement similar to the agreement rejected by the judge in the first employee’s case. The Appeals Court determined that the employees’ awards for pain and suffering were exempt from the insurer’s liens. The Supreme Judicial Court combined the two cases for argument and held that an insurer’s lien does not extend to damages allocated to an employee’s pain and suffering. View "DiCarlo v. Suffolk Constr. Co., Inc. v. Angelini Plastering, Inc." on Justia Law