Justia Massachusetts Supreme Court Opinion Summaries

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

Regency Transportation, Inc. is a Massachusetts S corporation that carries and delivers goods throughout the eastern United States. In 2010, the Commissioner of Revenue imposed a use tax on the full purchase price of each tractor and trailer in Regency’s fleet. The Commissioner subsequently denied Regency’s request for full abatement of the assessment. Regency appealed, arguing that the Commonwealth’s imposition of a use tax on vehicles engaged in interstate commerce violates the commerce and equal protection clauses of the Federal and State Constitutions. The Appellate Tax Board concluded that the motor vehicle use tax does not violate either the commerce or equal protection clauses. The Supreme Judicial Court affirmed, holding that an unapportioned use tax imposed on Regency’s interstate fleet of vehicles does not violate the commerce clause of the Federal Constitution. View "Regency Transp., Inc. v. Comm’r of Revenue" on Justia Law

Defendant sought an order requiring the Commonwealth to disclose whether a witness cooperating against him had previously served as a confidential informant or cooperating witness. The superior court judge granted Defendant’s request, concluding that prior cooperation by the witness could be relevant to demonstrating the witness’s bias or hope of benefit or reward. The Commonwealth filed a petition for relief pursuant to Mass. Gen. Laws ch. 211, 3. A single justice of the Supreme Judicial Court affirmed. The Supreme Judicial Court affirmed, holding that the Commonwealth failed to demonstrate the presence of exceptional circumstances to warrant the Court’s review of this interlocutory matter. View "Commonwealth v. Forlizzi" on Justia Law

Defendant was stopped by a state police trooper, who was prompted by the receipt of an anonymous 911 call concerning an apparent drunk driver. After a bench trial, Defendant was convicted of operating a motor vehicle while under the influence of alcohol. Defendant appealed, arguing that the trial court erred in denying his motion to suppress the evidence obtained during the warrantless stop of his vehicle because the stop was neither supported by reasonable suspicion nor made pursuant to an ongoing emergency. The appeals court affirmed the denial of Defendant’s motion to suppress, concluding that the information bore sufficient indicia of reliability, and therefore, the trooper could rely on the information in establishing reasonable suspicion to conduct an investigatory stop. The Supreme Judicial Court affirmed, holding that the information gathered from the anonymous call, corroborated by other information, was sufficiently reliable to warrant a finding that the trooper had reasonable suspicion to stop Defendant’s vehicle. View "Commonwealth v. Depiero" on Justia Law

Plaintiffs, a married couple, filed an application with the Department of Children and Families for a license that would enable them to become foster and preadoptive parents. The Department denied the application because of Plaintiffs’ use of corporal punishment as a form of discipline in their home. A hearing officer affirmed. Plaintiffs appealed, alleging that the Department’s decision was inconsistent with its regulations, was arbitrary and capricious, and was not supported by substantial evidence. Plaintiffs also argued that the Department’s decision impermissibly infringed on their right to the free exercise of their religion under the Federal and State Constitutions because physical discipline is an integral aspect of their Christian faith. The Supreme Judicial Court affirmed, holding (1) the Department’s decision to deny Plaintiffs’ application was supported by substantial evidence, was not arbitrary or capricious, and was based on a reasonable interpretation of its enabling legislation; and (2) the substantial burden that the Department’s decision imposed on Plaintiffs’ sincerely held religions beliefs was outweighed by the Department’s compelling interest in protecting the welfare of foster children. View "Magazu v. Dep’t of Children and Families" on Justia Law

Petitioner was the defendant in a criminal case in which he was charged with a single count of criminal harassment. Petitioner filed a motion to dismiss the complaint, alleging that the clerk-magistrate issued the complaint on the basis of perjured testimony at a show cause hearing. A district court judge denied the motion. Petitioner then filed a pleading seeking relief pursuant to Mass. Gen. Laws ch. 211, 3. A single justice of the Supreme Judicial Court denied the petition without a hearing. The full Court affirmed, holding that Petitioner failed to comply with S.J.C. Rule 2:21 in pursuing this appeal, and Petitioner’s claim failed on the merits. View "Afrasiabi v. Commonwealth" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on the theory of deliberate premeditation. Defendant appealed, asserting, among other claims, that he was entitled to a new trial because he was denied his constitutional right to the effective assistance of counsel for two reasons. The Supreme Judicial Court affirmed Defendant’s convictions and declined to exercise its authority to order a new trial or to reduce the verdict of murder in the first degree, holding (1) counsel’s alleged errors were not likely to have influenced the jury’s conclusion; and (2) Defendant’s claims that various errors were made by the prosecutor and judge were without merit. View "Commonwealth v. Gonzalez" on Justia Law