Justia Massachusetts Supreme Court Opinion Summaries

In reliance on the advice of her investment advisor, Morgan Financial Advisors, Inc. (MFA), Plaintiff invested three-quarters of her retirement savings in a hedge fund that became insolvent, resulting in the loss of her entire investment. Plaintiff filed suit against MFA and its sole owner and officer (collectively, Defendants) alleging that Defendants violated the Massachusetts Uniform Securities Act (Act), committed fraud, and breached their fiduciary duty to her. The trial judge concluded that Defendants were liable under the Act and entered judgment in Plaintiff’s favor. The Supreme Judicial Court affirmed, holding (1) the district judge did not err in finding that Defendants were “sellers” of securities under the Act; (2) Plaintiff timely filed her action under the Act; and (3) the evidence was sufficient to support the convictions. View "Hays v. Ellrich" on Justia Law

Defendant, a police officer, was charged with assault and battery by means of a dangerous weapon and assault and battery for beating an unarmed civilian after responding to another officer’s request for assistance with a traffic stop. After a jury trial, Defendant was found guilty of both charges. The Supreme Judicial Court affirmed, holding (1) the trial judge’s jury instructions were erroneous in that (i) they failed to acknowledge that Defendant was a police officer and that he was entitled to use force in carrying out his official duties if necessary and reasonable, and (ii) the self-defense instructions included an erroneous statement that Defendant had a duty to retreat if possible under the circumstances; and (2) the errors were not prejudicial. View "Commonwealth v. Asher" on Justia Law

Defendants in this case were licensed Massachusetts real estate brokerage firms and some of their members and shareholders. Defendants classified Plaintiffs, licensed real estate salespersons, as independent contractors. Plaintiffs filed a complaint alleging, inter alia, that Defendants violated the independent contractor statute by not classifying Plaintiffs as employees. On this count of the complaint, the trial judge granted partial summary judgment in favor of Defendants, concluding that the independent contractor statute did not control under these circumstances to the salespersons in this industry. The Supreme Judicial Court affirmed, holding that the superior court judge did not err in concluding that the independent contractor statute does not apply to real estate salespersons. View "Monell v. Boston Pads, LLC" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree, assault with intent to kill, and assault and battery by means of a dangerous weapon. Defendant appealed, assigning error to several evidentiary rulings made by the trial judge. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) to the extent the trial judge erred in failing to instruct the jurors that they could consider Defendant’s custodial statements as evidence of consciousness of guilt if the Commonwealth proved that the statements were false, the error did not influence the jury; (2) the trial judge did not err in admitting a witness’s statement made on a 911 call; (3) the trial judge was within her discretion in excluding third-party culprit evidence; (4) the trial judge properly excluded certain evidence of the police investigation; and (5) the trial judge did not err in denying Defendant access to the treatment records of a Commonwealth witness or in limiting cross-examination of that witness. View "Commonwealth v. Alcantara" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. Defendant was sixteen years old at the time of the murder. Defendant subsequently filed a motion to reduce the verdict to murder in the second degree. The trial judge granted the motion. After Defendant was resentenced, he filed a notice of appeal. Defendant then filed a motion for a new trial arguing that his Sixth Amendment right to a public trial was violated when the courtroom was closed during jury empanelment. The motion was denied, and Defendant appealed. The Supreme Judicial Court affirmed, holding that the lower court (1) did not err in reducing the verdict to murder in the second degree based on the facts of this case; and (2) did not err in failing to instruct the jury on involuntary manslaughter based on Defendant’s mental impairment of ADHD and depression in an adolescent brain. View "Commonwealth v. Pagan" on Justia Law

The Walter E. Fernald Corporation, a charitable organization, brought this action in the Land Court seeking a declaration that it was the owner of certain parcels of unrecorded land. The Commonwealth had asserted ownership of the parcels. The Commonwealth filed a motion to dismiss on the grounds of sovereign immunity. A Land Court judge denied the motion to dismiss and allowed the Corporation’s motion for summary judgment. The Supreme Judicial Court affirmed, holding (1) sovereign immunity does not apply to the particular type of action brought here; and (2) although a school established by the Corporation became an agency of the Commonwealth in the early 1900s, the Corporation remained independent of the Commonwealth and purchased the parcels on its own behalf. View "Walter E. Fernald Corp. v. The Governor" on Justia Law

Defendant, a juvenile, was indicted as a youthful offender for possession of heroin with intent to distribute. Under the youthful offender statute, a juvenile may be prosecuted as an adult if the charge involves the “infliction or threat of serious bodily harm.” Defendant moved to dismiss the indictment, arguing that the Commonwealth presented insufficient evidence to the grand jury to establish this requirement where his offense was the mere possession of heroin with intent to distribute. The juvenile court denied the petition. The Supreme Judicial Court disagreed and reversed the decision of the single justice denying Defendant’s Mass. Gen. Laws ch. 211, 3 petition, holding that evidence of the generalized potential for harm from the sale or use of heroin, without more, does not meet the probable cause standard for “infliction or threat of serious bodily harm.” View "Felix F. v. Commonwealth" on Justia Law

Petitioner was charged with unarmed robbery and assault and battery. Notices were sent to Petitioner from three different courts alleging that Petitioner had violated the terms of his probation by committing the new offenses. The Boston Municipal Court judge found “no violation of probation” with respect to the new offenses. Petitioner then filed a motion in the New Bedford District Court and the Fall River District Court to hold the Commonwealth bound by the order of the Boston Municipal Court. Petitioner’s motion was denied. Thereafter, Petitioner filed a petition for relief in the county court pursuant to Mass. Gen. Laws ch. 211, 3, alleging that because the Boston Municipal Court had issued a final judgment deciding that he had not violated the terms of his probation by committing the new offenses, collateral estoppel barred a subsequent probation revocation proceeding in a different county on the new offenses. A single justice reserved and reported the case to the full court. The Supreme Judicial Court allowed the petition for relief, holding that principles of collateral estopped barred the Commonwealth from relitigating the same factual issue of whether Petitioner violated the terms of his probation with respect to the new offenses at subsequent probation revocation proceedings. View "Kimbroughtillery v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of one count of assault and battery against his sister. During trial, Defendant’s principal contention was that his sister and her boyfriend fabricated their allegations against him in order to justify the boyfriend’s actions of attacking Defendant and accidentally injuring the sister in the process. The Supreme Court reversed and remanded for a new trial, holding that the trial judge abused his discretion in refusing to allow Defendant to pursue his theory through extrinsic evidence and examination of the two witnesses because, if the evidence was credited by the jury, it would have supported an inference of bias, prejudice, and motive to prevaricate. View "Commonwealth v. Magdalenski" on Justia Law

A stock transfer restriction required a selling shareholder first to offer his stock to the company at his desired price and then, if the company rejected it, to offer it at a price to be determined by arbitrators. Plaintiff invoked this process by tendering an offer to the company (Defendant) but later changed his mind regarding his desire to sell. When Plaintiff sought to withdraw from the process of valuing his stock, Defendant moved to compel arbitration. The superior court denied the motion to compel, concluding that a mere disagreement over the value of stock was legally insufficient to give rise to arbitration. The Supreme Judicial Court affirmed on other grounds, holding (1) a stock valuation may be conducted through arbitration so long as an actual controversy exists regarding the value of the stock; and (2) because the shareholder in this case decided not to sell the stock prior to the commencement of arbitration, the controversy to be arbitrated was rendered moot. View "Vale v. Valchuis" on Justia Law