Justia Massachusetts Supreme Court Opinion Summaries

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

Petitioners were three individuals who pleaded guilty to various drug offenses in cases where Annie Dookhan, a chemist employed in the forensic drug laboratory of the William A. Hinton State Laboratory Institute who committed egregious misconduct, signed the certificates of drug analysis. Petitioners filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 asking that if they exercise their right to postconviction relief they should not receive harsher punishment. The Committee for Public Counsel Services (CPCS) moved to intervene, arguing that the Court should implement a “global remedy” to resolve the myriad cases affected by Dookhan’s egregious misconduct. The Supreme Judicial Court granted the motion to intervene and granted relief in part, holding, primarily, (1) a defendant who has been granted a new trial based on Dookhan’s misconduct cannot be charged with a more serious offense than that of which he or she was initially convicted and, if convicted again, cannot be given a more severe sentence than that which was originally imposed; and (2) a so-called “global remedy” will not be implemented at this time. The remainder of the Court’s holdings concerned evidentiary rules to be followed in the event a “Dookhan defendant” pursues a motion to withdraw a guilty plea. View "Bridgeman v. Dist. Attorney for Suffolk Dist." on Justia Law

Property owners sued the City of New Bedford seeking damages arising from soil contamination around a site that the City had operated as an unrestricted ash dump. The City retained a consultant at TRC Environmental Corporation (TRC) to prepare documents to assist the city solicitor in advising the City as to the potential litigation. The City then filed a third-party complaint alleging cost recovery claims against various third-party defendants. During discovery, some third-party defendants moved to compel production of the TRC documents. The motion judge allowed the motion, thus rejecting the City’s claim that the TRC work product was protected by the attorney-client privilege and the work product doctrine. The Supreme Judicial Court vacated the judge’s order, holding (1) “opinion” work product and “fact” work product that was prepared in anticipation of litigation generally falls outside the definition of “public records” under Mass. Gen. Laws ch. 4, 7(26); and (2) where work product is exempted from disclosure under the public records act, it is protected from disclosure in discovery to the extent provided by Mass. R. Civ. P. 26. View "DaRosa v. City of New Bedford" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree based on deliberate premeditation. Defendant was convicted on a theory of joint venture with the shooter, who took the gun from Defendant’s hand and began shooting. The Supreme Judicial Court vacated Defendant’s conviction on the murder charges and remanded for a new trial on those indictments, holding that the judge erred in misstating the law of joint venture in her response to a jury question, and the error created a substantial likelihood of a miscarriage of justice because the response to the jury’s question obscured or eliminated the possibility that Defendant could be convicted of any lesser offense. View "Commonwealth v. Tavares" on Justia Law

When a fire caused by NSTAR Electric and Gas Company employees damaged a building owned by the Massachusetts Institute of Technology (MIT), two insurers paid the claims of the building’s tenants. The insurers then brought this complaint against NSTAR Electric Company and NSTAR Electric & Gas Company (collectively, NSTAR) seeking to recover for the claims paid. NSTAR moved for partial summary judgment, contending that, to the extent to which the insurers sought recovery for business interruption losses, the claims were barred by Massachusetts Department of Telecommunications and Energy Tariff No. 200A, filed with and approved by the Department of Public Utilities, and in effect when the explosion occurred. The tariff contained a limitation of liability clause that limited NSTAR from liability to nonresidential customers for special, indirect, or consequential damages resulting from the utility’s gross negligence. A judge of the superior court allowed NSTAR’s motion for partial summary judgment, concluding that a tariff filed with and approved by a regulatory agency may limit a public utility’s liability. The Supreme Judicial Court affirmed, holding that the limitation of liability clause in the tariff precluded Plaintiffs’ claims to recover for business interruption and other consequential or economic damages. View "Maryland Cas. Co. v. NSTAR Elec. Co." on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. Defendant filed a direct appeal and also appealed the denial of his motion for a new trial. The Supreme Judicial Court affirmed the conviction and the order denying Defendant’s motion for a new trial and declined to exercise its power under Mass. Gen. Laws ch. 278, 33E, holding (1) the judge considering Defendant’s motion for a new trial did not abuse its discretion in denying the motion without an evidentiary hearing; (2) assuming, without deciding, that the Commonwealth failed to timely disclose exculpatory evidence, the nondisclosure did not result in a substantial likelihood of a miscarriage of justice; (3) the prosecutor did not commit prosecutorial misconduct; and (4) Defendant’s trial counsel did not provide ineffective assistance. View "Commonwealth v. Vaughn" on Justia Law

At Defendant’s trial for murder and conspiracy, the prosecution’s theory was that Defendant had hired an assassin to kill the victim. Defendant testified on his own behalf, refuting the allegations. After the jury was charged, it was discovered that Defendant had suffered a stroke that had occurred on the night between the first and second days of his testimony. The jury never learned of Defendant’s stroke and returned guilty verdicts on both indictments. The trial judge ordered a new trial, determining that Defendant’s then-undetected stroke might have so affected the course of his testimony as to damage his credibility in the jury’s eyes, and given the importance of the jury’s assessments of credibility in this case, justice may not have been done. The Supreme Judicial Court affirmed, holding that, in the highly unusual circumstances presented here, there was no abuse his discretion in the judge’s decision that “justice may not have been done.” View "Commonwealth v. Brescia" on Justia Law

Petitioners, J.S. and V.K., a married same-sex couple, filed a joint petition for adoption seeking to adopt their son Nicholas. Nicholas was conceived through in vitro fertilization using a known sperm donor and was born to J.S. Petitioners filed a motion to proceed with the adoption without further notice, arguing that no consent other than their consent was necessary, and no notice to any other person was required. A probate and family court judge denied Petitioners’ motion and reported the following question: Must the lawful parents of a child give notice to the known biological father/sperm donor pursuant to Mass. Gen. Laws ch. 210, 2 in conjunction with their petition for adoption? The Supreme Judicial Court answered the question in the negative, holding that Mass. Gen. Laws ch. 210, 2 does not require the lawful parents of a child to give notice of the petition for adoption to a known sperm donor. View "Adoption of a Minor" on Justia Law

Defendants were creditors of Plaintiff who obtained final judgments against Plaintiff. A levy of execution was made on Plaintiff’s real property. Plaintiff subsequently received a discharge under Chapter 7 of the Bankruptcy Code. Plaintiff did not seek or obtain a ruling from the Bankruptcy Court avoiding any of Defendants’ liens. Thereafter, Plaintiff filed a complaint to remove the judicial liens. The judge entered judgment in favor of all three defendants, including two defaulting defendants, ruling that Defendants’ liens remained. The Supreme Judicial Court affirmed, holding that Defendants’ liens survived the bankruptcy discharge as a matter of federal and state law. View "Christakis v. Jeanne D’Arc Credit Union" on Justia Law

After a jury trial, Defendant was convicted of killing his wife with deliberate premeditation. The Supreme Judicial Court affirmed the conviction and declined to exercise its powers under Mass. Gen. Laws ch. 278, 33E, holding that the trial court did not err in (1) admitting two postmortem photographs depicting the victim’s body; (2) failing to grant a mistrial after the medical examiner testified that the victim’s death was a homicide, when the defense was that it was a suicide, where the judge promptly struck the improper testimony and gave a highly specific curative instruction; (3) admitting Defendant’s statements to police with no redactions; and (4) failing to conduct a voir dire of jurors after at least one juror had been exposed to prejudicial extraneous material. View "Commonwealth v. Amran" on Justia Law