Justia Massachusetts Supreme Court Opinion Summaries

Petitioner was convicted of two counts of assault and battery on a police officer, resisting arrest, disturbing the peace, and disorderly conduct. More than twenty months after he was sentenced, Petitioner filed a motion with the Appellate Division of the superior court requesting that the Appellate Division accept an appeal of his sentences to the house of correction. See Mass. Gen. Laws ch. 278, 28A-28C. The motion was denied. Petitioner then filed a petition pursuant to Mass. Gen. Laws ch. 211, 3. A single justice of the Supreme Judicial Court denied relief. The Supreme Judicial Court affirmed, holding that the challenged sentences were not within the jurisdiction of the Appellate Division because the sentence was not a felony sentence to the State prison. View "Starks v. Commonwealth" on Justia Law

Jay Simkin filed complaints with the Board of Bar Overseers (Board) alleging that certain attorneys committed breaches of the rules of professional conduct in connection with proceedings involving the revocation and reinstatement of Simkin’s license to carry firearms. Bar counsel investigated the complaints but declined to pursue them. After review, the Board determined not to proceed. Simkin subsequently filed a petition requesting that the Supreme Judicial Court enter findings that the attorneys had violated the rules of professional conduct, which, Simkin claimed, would lead to bar counsel’s reconsideration of her decision not to pursue his complaints against the attorneys. A single justice of the Court denied relief. The Supreme Judicial Court affirmed, holding that Simkin had no further standing in the matter, as a private individual cannot prosecute a judicial action for attorney discipline. View "In re Simkin" on Justia Law

David Forlizzi and Fred Battista (together, Petitioners) were indicted on similar charges arising out of Petitioners’ alleged misconduct in connection with a prior trial involving alleged insurance fraud. Petitioners moved to dismiss the indictments, alleging that the Commonwealth had engaged in prosecutorial misconduct during the investigation leading to the indictments. A superior court judge denied the motion, concluding that the prosecutors had engaged in overreaching but that dismissal of the indictments as a sanction was not warranted under the circumstances. Petitioners filed a petition in the county court pursuant to Mass. Gen. Laws ch. 211, 3 seeking interlocutory review. A single justice of the Supreme Judicial Court denied relief, concluding that Petitioners had not shown they were entitled to extraordinary relief. The Supreme Judicial Court affirmed the denial of the petition on the ground that Petitioners failed to demonstrate irremediable error. View "Forlizzi v. Commonwealth" on Justia Law

In November 2012, voters approved the Commonwealth’s new medical marijuana law. In May 2013, Defendant was charged with possession with the intent to distribute marijuana, distribution of marijuana, and conspiracy to violate the drug laws. The charges arose from a search of Defendant’s property pursuant to a search warrant issued in May 2013. Defendant filed a motion to suppress the evidence obtained pursuant to the warrant. The district court allowed Defendant’s motion, concluding that the affidavit filed in support of the search warrant application demonstrated probable cause that Defendant was cultivating marijuana at the property but, in light of the act, failed to establish probable cause that Defendant was not authorized to do so and therefore was committing a crime. The Supreme Judicial Court affirmed, holding that the affidavit failed to establish probable cause for the search. View "Commonwealth v. Canning" on Justia Law

Plaintiffs in these consolidated cases leased taxicabs and licenses, called “medallions,” for each taxicab. Plaintiffs claimed that they were employees of certain taxicab owners, radio associations, and a taxicab garage (collectively, Defendants) but were misclassified as independent contractors. Defendants argued that their relationships with Plaintiffs must be considered in the context of a municipal regulation (Rule 403), which explicitly permits drivers to operate as independent contractors. Plaintiffs argued that the municipal regulation could not override the independent contractor statute, under which an individual performing any service is presumed to be an employee. The superior court concluded that Plaintiffs provided a service to Defendants but denied summary judgment on the grounds that genuine issues of material fact existed as to whether the provision of taxi services was within the usual course of Defendants’ businesses. The Supreme Judicial Court vacated the lower court’s order, holding (1) Rule 403 is not contrary to the policies undergirding the independent contractor statute; and (2) because the the medallion owners and radio associations had, in complying with Rule 403, satisfied each prong of the independent contractor test, summary judgment should have been granted to those defendants on count one of the complaints, misclassification as independent contractors. View "Sebago v. Boston Cab Dispatch, Inc." on Justia Law

After a jury-waived trial, Plaintiff was found guilty of malicious destruction of property, breaking and entering in daytime, and larceny over $250. The Appeals Court reversed Plaintiff’s convictions, concluding that the Commonwealth’s evidence was insufficient to support the convictions. Thereafter, Plaintiff filed a complaint under Mass. Gen. Laws ch. 258D, the erroneous convictions statute, seeking compensation for his erroneous convictions. The Commonwealth filed a motion to dismiss Plaintiff’s complaint, arguing that Plaintiff did not meet his threshold burden of proving that his convictions were overturned “on grounds which tend to establish [his] innocence” under the erroneous convictions statute. A judge denied the motion. The Commonwealth appealed. The Supreme Judicial Court affirmed the denial of the motion to dismiss, holding that the reversal of Plaintiff’s convictions due to insufficient evidence amounted to grounds which tend to establish Plaintiff’s innocence, thus rendering Plaintiff eligible to obtain relief under the erroneous convictions statute. View "Renaud v. Commonwealth" on Justia Law

Plaintiff, a former school principal of six years in the Town of Erving, sought contribution by the Town to the cost of her group health insurance premiums. The Town had adopted Mass. Gen. Laws ch. 32B, 9E (“the statute”), which required it to contribute over fifty percent of the health insurance premiums of all of its retirees. Before employing Plaintiff, however, the Town enacted a policy under which it would only contribute to the group health insurance premiums of retired employees who had retired after a minimum of ten years of employment with the Town. Consequently, the Town determined that Plaintiff was not eligible for contribution by the Town to her health insurance premiums. Plaintiff filed suit asserting that the Town violated her right to payment to a portion of her group medical insurance premiums as statutorily required. The superior court entered judgment in favor of Plaintiff and issued a permanent injunction prohibiting the Town from enforcing its policy. The Supreme Judicial Court affirmed, holding (1) the terms of the statute govern whether and in what amounts the Town must contribute to the cost of a retiree’s health insurance premiums; and (2) the Town’s retirement policy imposing a minimum term of service as a prerequisite to premium contributions from the Town is invalid. View "Galenski v. Town of Erving" on Justia Law

When Samantha Reckis was seven years old, she developed toxic epidermal necrolysis, a life-threatening skin disorder, after receiving multiple doses of Children’s Motrin, an over-the-counter medication with ibuprofen as its active ingredient. Plaintiffs, Samantha and her parents, sued the manufacturer and marketer of Children’s Motrin and its parent company, alleging that Samantha developed TEN as a result of being exposed to ibuprofen in the Children’s Motrin and that the warning label on the medication’s bottle rendered the product defective because it failed to warn consumers about the serious risk of developing a life-threatening disease from it. A jury found in favor of Plaintiffs and awarded Samantha a total of $50 million in compensatory damages and each of Samantha’s parents $6.5 million for loss of consortium. The Supreme Judicial Court affirmed, holding (1) Plaintiffs’ claim of failure to warn was not preempted by the Federal Food, Drug, and Cosmetic Act; (2) a pharmacologist who offered the causation evidence essential to Plaintiffs’ case was qualified to testify as to specific medical causation, and the testimony was reliable and admissible; and (3) the damages awarded to each of the plaintiffs were not grossly excessive or unsupported by the record. View "Reckis v. Johnson & Johnson" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree, the unlawful possession of a firearm, and the unlawful possession of ammunition. Defendant was sentenced to a mandatory sentence of life imprisonment for the murder conviction. Defendant’s motion for a new trial was denied. Defendant appealed, arguing, among other claims, that the trial judge erred in denying his request to instruct the jury on duress. The Supreme Judicial Court affirmed the convictions, holding (1) juveniles, along with adults, are generally barred from using a duress defense for intentional murder; (2) Defendant procedurally waived his Sixth Amendment right to a public trial during the jury empanelment, and therefore, his right to a public trial was not violated when the courtroom was closed for a period of sixty to ninety minutes during jury empanelment; and (3) Defendant was not prejudiced by a noncitizen juror deciding his case. View "Commonwealth v. Jackson" on Justia Law

At issue in this case was a 2006 amendment to the “obsolete mortgage” statute, under which a mortgage becomes unenforceable after a certain number of years. A mortgage in which the term or maturity date is stated becomes unenforceable five years after the expiration of the term, and a mortgage in which the term or maturity date is not stated becomes unenforceable thirty-five years after recording. Here, Defendant conducted a foreclosure auction purporting to sell certain property that secured two mortgages held by Defendant. At the time, both mortgages would be unenforceable under the amended obsolete mortgage statute if the five-year statute of limitations was applicable. Plaintiff sought a declaration that the mortgages were discharged under the obsolete mortgage statute and that the foreclosure auction was null and void. A land court judge granted partial summary judgment for Plaintiff, concluding that a reference in the mortgages to the term of the underlying debt was sufficient to state the “term or maturity date of the mortgage.” The Supreme Judicial Court affirmed, holding (1) the two mortgages were subject to the five-year period and thus were discharged under the obsolete mortgage statute; and (2) the application of the statute in this case did not violate due process and contracts clause protections. View "Deutsche Bank Nat’l Trust Co. v. Fitchburg Capital, LLC" on Justia Law