Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of murder in the first degree, on theories of deliberate premeditation and felony-murder, and armed robbery. The motion judge dismissed the armed robbery conviction as duplicative. Defendant appealed, arguing that the motion judge erred in denying his motion to suppress evidence seized from his room in a “sober house” pursuant to a search warrant, alleging that there was no probable cause that he was the perpetrator. The Supreme Judicial Court affirmed the convictions and declined to reduce the verdict of murder to a lesser degree of guilt or to grant a new trial, holding (1) the motion judge did not err in denying Defendant’s motion to suppress, as there was probable cause to issue a search warrant; (2) because Defendant was convicted of murder on theories of both premeditation and felony murder and because the Court affirmed on both theories, the conviction of armed robbery was not duplicative and should not have been dismissed; and (3) there was no reason to reduce the verdict of murder in the first degree or to order a new trial. View "Commonwealth v. Foster" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on a theory of extreme atrocity or cruelty and possessing a firearm without a license. The Supreme Judicial Court affirmed the convictions, holding that the trial judge (1) did not err in denying Defendant’s motion to suppress statements he made to police following his arrest, as Defendant voluntarily waived his Miranda rights, and his statements were voluntary; and (2) did not deprive Defendant of a defense by declining to instruct the jury on the uncharged offense of accessory after the fact where the judge’s instructions clearly indicated that Defendant could not be convicted of murder if the jury concluded that Defendant’s role was indeed limited to aiding in the shooter’s escape from the police. View "Commonwealth v. Newson" on Justia Law

A franchisee janitorial worker, on behalf of himself and other similarly situated individuals, filed a complaint against System4 LLC, a master franchisor, and NECCS, Inc., a regional subfranchisor, alleging, among other claims, breach of contract, misclassification as independent contractors in their franchise agreements, and rescission of the franchise agreements. The franchise agreements, signed only by Plaintiffs and NEECS, required the franchisees to arbitrate virtually all disputes. Defendants, citing the arbitration clause in the franchise agreement, moved to stay the court proceedings pending arbitration. The judge concluded that because System4 was not a nonsignatory to the agreements, Plaintiffs could proceed to litigate their claims against System4 in court. The Supreme Judicial Court reversed, holding that, by reason of equitable estoppel, System4 could compel Plaintiffs to arbitrate their substantive claims in accordance with the arbitration provision in Plaintiffs’ franchise agreements. Remanded. View "Machado v. System4 LLC" on Justia Law

After a jury-waived trial, Defendant was convicted of trafficking in heroin and cocaine and of unlawful possession of marijuana with intent to distribute. Defendant appealed the denial of his motion to suppress evidence obtained from his apartment by police officers during the execution of an “anticipatory search warrant,” claiming that the officers had executed the search before the “triggering events” stated in the affidavit had occurred. The Supreme Judicial Court affirmed the denial of the motion to suppress and the resulting convictions, holding (1) where, as in this case, the Commonwealth applies for an anticipatory search warrant and the judicial authorization to execute the search is conditioned on the occurrence of a specific future event, the search is authorized by the warrant where there is equivalent compliance with that condition precedent; and (2) in this case, there was both equivalent compliance with the warrant’s triggering conditions, and compliance with those conditions provided probable cause to search Defendant’s residence. View "Commonwealth v. Colondres" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree and assault and battery by means of a dangerous weapon on a person sixty years of age or older. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) the trial court did not err by not explicitly instructing the jury that when considering whether to accept Defendant’s statements to law enforcement under the human practice rule, they were entitled to evaluate the validity of his Miranda waiver as a factor; (2) the judge’s instructions regarding Defendant’s defense of mental impairment did not give rise to a substantial likelihood of a miscarriage of justice; (3) Defendant’s convictions and sentences were not duplicative; and (4) the trial judge’s action of designating a sleeping juror as an alternate did not amount to a substantial likelihood of a miscarriage of justice. View "Commonwealth v. The Ngoc Tran" on Justia Law

Plaintiffs, current and former employees at Dunkin’ Donuts stores, brought suit against Defendants, a Dunkin’ Donuts franchisee and the entity that performed management functions for those stores, alleging that Defendants had implemented a no-tipping policy at some of their stores in violation of Mass. Gen. Laws ch. 149, 152A (the Tips Act). The superior court granted summary judgment for Defendants, concluding that the no-tipping policy was not a violation of the Tips Act. The Supreme Judicial Court affirmed, holding (1) the Tips Act allows an employer to maintain a no-tipping policy; (2) an employer may be liable under the Tips Act if the employer fails clearly to communicate the no-tipping policy to customers, who subsequently leave tips that are retained by the employer; and (3) an employer may not be held liable if the employer clearly communicates the no-tipping policy to customers, who nonetheless leave tips that are retained by the employer. View "Meshna v. Scrivanos" on Justia Law

Defendant was convicted of murder in the second degree for the shooting of a fourteen-year-old. Defendant was seventeen years and five months old at the time of his arrest for the shooting. Defendant appealed the district court’s denial of his motion to suppress incriminating statements that he made to the police after waiving his Miranda rights, arguing that their introduction at trial was error given the common-law rule that, ordinarily, a juvenile must be given a meaningful opportunity to consult with an interested adult before waiving his Miranda rights, an opportunity he did not have. Several years after Defendant was convicted, the Legislature enacted St. 2013, ch. 2013 (2013 act), which amended various statutory provisions to treat seventeen year olds as juveniles. The Supreme Judicial Court affirmed Defendant’s conviction, holding (1) the 2013 act did not affect this case because it is prospective in its application and does not modify the interested adult rule; but (2) the interest adult rule is now extended, on a prospective basis, to seventeen year old defendants. View "Commonwealth v. Smith" on Justia Law

K.I. was committed to Walden Behavioral Care (Walden), a facility for the treatment of mentally ill patients, for a three-day period, during which a psychiatrist provided diagnosis of and treatment to K.I. Walden then brought a petition seeking K.I.’s continuing commitment. K.I. filed a motion in limine to exclude the psychiatrist’s testimony regarding K.I.’s statements, asserting that his statements were protected by the psychotherapist-patient privilege, as defined in Mass. Gen. Laws ch. 233, 20B. A district judge denied the motion, determining that the exception provided by section 20B(b) was inapplicable because the psychotherapist-patient privilege was overcome by the imminent harm exception to the privilege set forth in Mass. Gen. Laws ch. 233, 20B(a). At the commitment hearing, the psychiatrist was permitted to testify to K.I.’s statements and to his opinion that K.I. was suicidal. K.I. was committed to Walden for six months. The Supreme Judicial Court affirmed, holding (1) the exception to the psychotherapist-patient privilege established in section 20B(a) applied under these circumstances; and (2) the district court judge did not err in permitting the psychiatrist to testify at the involuntary commitment hearing concerning K.I.’s statements. View "Walden Behavioral Care v. K.I." on Justia Law

After a jury trial, Defendant was convicted on two indictments charging indecent assault and battery on a child under fourteen, in violation of Mass. Gen. Laws ch. 265, 13B, and one indictment charging dissemination of matter harmful to minors, in violation of Mass. Gen. Laws ch. 272, 28. The Supreme Judicial Court affirmed the convictions, holding (1) during the time period alleged in the indictment, section 28 was not unconstitutionally over broad because, contrary to Defendant's assertions, the statute implicitly required a defendant’s knowledge that the person receiving the harmful matter was a minor; and (2) the prosecutor’s suggestion that the defendant would have committed further sexual offenses against one of the child victims had the child not moved away was improper but, in the context of the entire closing argument, did not create a substantial risk of a miscarriage of justice. View "Commonwealth v. Jones" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of felony-murder, unlawful possession of a firearm, and unlawful possession of a loaded firearm. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress a letter he wrote to another detainee while he was detained awaiting trial; (2) the trial court did not err by not instructing, sua sponte, on involuntary manslaughter based on wanton or reckless conduct; and (3) Defendant’s trial court was ineffective in not requesting an instruction on involuntary manslaughter based on wanton or reckless conduct. View "Commonwealth v. Jessup" on Justia Law