Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court dismissed this appeal of the judgment of a single justice of the court denying Petitioner's petition for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the appeal was moot.After judgment entered against Petitioner in a summary process action Petitioner appealed, challenging the denial of her motions to stay execution of that judgment on the basis of illness. The Housing Court denied relief. Petitioner then sought a stay on the same ground, which a single justice of the Appeals Court denied. Petitioner subsequently petitioned the single justice of the Supreme Judicial Court seeking a stay of execution on the basis of illness. The Supreme Judicial Court dismissed the matter, holding that the matter was moot because the eviction Petitioner sought to stay had already occurred. View "Kahyaoglu v. Sillari Enterprises LLC" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3 from an order of the housing court requiring him to make use and occupancy payments, holding that the single justice properly denied the petition.Petitioner appealed from the entry of final judgment in favor of Respondent in a summary process action. A housing court judge granted Petitioner's motion to waive the appeal bond and ordered him to make monthly use and occupancy payments during the pendency of the appeal. Petitioner sought interlocutory review, and the single justice affirmed. Petitioner then brought the instant petition seeking a reduction in the monthly use and occupancy payments, without success. After the deadline passed for tendering the outstanding use and occupancy payments Petitioner filed a motion requesting an extension. The single justice denied the motion. The Supreme Judicial Court affirmed, holding that the single justice properly denied relief. View "Cummins Realty Trust v. O'Neill" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that Petitioner had no standing to obtain extraordinary relief in the instant matter.Petitioner filed an application in the district court for a criminal complaint charging an individual with witness intimidation and unlawful wiretapping. The application was denied due to lack of probable cause. Thereafter, Petitioner filed another application for criminal complaint in the Boston Municipal Court (BMC) charging the same individual with witness intimidation. The BMC found no probable cause and did not issue the complaint. Petitioner then brought this action, and the single justice denied relief without addressing the merits. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused his discretion in denying relief. View "In re Two Applications for a Criminal Complaint" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief under the statute.Petitioner was charged with one count each of assault and battery and witness intimidation. After an evaluation, a doctor recommended that Petitioner be found incompetent to stand trial and that he remain in the Tewksbury State Hospital, where he had been involuntarily committed for evaluation. Petitioner's counsel stipulated to incompetency but objected to further commitment. Petitioner was ultimately involuntarily committed for an additional thirty days. Petitioner then brought this petition asking the single justice to vacate the involuntary commitment order. The single justice denied the petition without holding a hearing. The Supreme Court affirmed, holding that Petitioner had an adequate alternative remedy. View "In re Impounded Case" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court in favor of Cummings Properties, LLC in this suit brought to enforce Darryl Hines's obligations as guarantor of a commercial lease, holding that Hines failed to meet his burden to prove that the amount provided for in the lease's liquidated damages clause was an unreasonable forecast of damages at the time the lease was signed.At issue was whether a liquidated damages clause in the lease was unenforceable where Hines's company defaulted on the rent but Cummings was able to relet the property. The trial judge found in favor of Cummings and awarded it the balance owed under the lease's liquidated damages clause. The appeals court reversed, determining that the liquidated damages provision was an unenforceable penalty because it did not account for the possibility that Cummings could, in mitigation of Hines's breach, relet the premises and collect rent. The Supreme Judicial Court affirmed, holding (1) this Court has never required that the amount of a liquidated damages clause take into account any future rents collected from a new tenant to be enforceable; and (2) Hines failed to meet his burden to show that the liquidated damages clause was unenforceable. View "Cummings Properties, LLC v. Hines" on Justia Law

The Supreme Court affirmed the judgment of the county court dismissing Petitioner's complaint seeking an order holding the Board of Registration in Medicine in contempt of an order of the Supreme Court, holding that the complaint was properly dismissed.After his license lapsed, Petitioner, who had been the subject of two disciplinary proceedings before the Board, filed a petition seeking immediate reinstatement of his license. Before the case could be heard, the Board agreed to reinstate Petitioner's license, and the parties entered into a voluntary stipulation of dismissal. Thereafter, the Board summarily suspended Petitioner's license because a second disciplinary proceeding had commenced against him. Petitioner then filed a complaint for civil contempt alleging that the temporary suspension was in contempt of the voluntary stipulation of dismissal. The complaint was dismissed without a hearing. The Supreme Judicial Court affirmed, holding that the third single justice properly dismissed the complaint. View "Bock v. Bd. of Registration in Medicine" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree based on a theory of felony-murder, among other charges, holding that a police officer's identification testimony was admitted improperly, but its admission did not prejudice Defendant.On appeal, Defendant challenged the denial of his motion to suppress, among numerous other allegations of error. For the claimed errors, Defendant requested that the court reduce his verdict or order a retrial. The Supreme Judicial Court affirmed, holding (1) a police officer's testimony identifying Defendant in a video recording at trial was improperly admitted, but the admission did not prejudice Defendant; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Fisher" on Justia Law

In this case involving a facility that operated under the protection of a thirty-six-year-old consent decree the Supreme Judicial Court held that the trial judge did not abuse her discretion in concluding that the Department of Developmental Services failed to establish that the consent decree should be terminated based on the evidentiary record before the probate court.In question was the treatment and welfare of individuals who suffered from severe developmental and intellectual disabilities that caused them to engage in grievous self-harm and other life-threatening behaviors. The individuals lived in group homes under the care of Judge Rotenberg Educational Center, Inc. (JRC), a facility that employed the use of aversive interventions such as electric skin shock as part of its treatment approach. In the 1980s and 1990s State agencies disrupted JRC's operations, after which the consent decree was issued. Years later, the agencies bound by the decree moved for its termination, but the probate and family court denied the motion. The Supreme Judicial Court affirmed, holding that the Department's arguments against continued enforcement of the consent decree were unavailing. View "Judge Rotenberg Educational Center, Inc. v. Commissioner of Dep't of Developmental Services" on Justia Law

The Supreme Judicial Court held that the Secretary of the Commonwealth did not overstep the bounds of the authority granted to him under the Massachusetts Uniform Securities Act (MUSA), Mass. Gen. Laws ch. 110A, by promulgating the "fiduciary duty rule."The Secretary brought an administrative enforcement proceeding alleging that Plaintiff Robinhood Financial LLC violated the prohibition in Mass. Gen. Laws ch. 110A, 204(a)(2)(G) against "unethical or dishonest conduct or practices in the securities, commodities or insurance business" by dispensing ill-suited investment advice to unsophisticated investors. The Secretary defined the phrase in section 204(a)(2)(G) to require broker-dealers that provide investment advice to retail customers to comply with a statutorily-defined fiduciary duty. Thereafter, Plaintiff brought the instant action challenging the validity of the fiduciary duty rule. The superior court concluded that the Secretary acted ultra vires to promulgating the rule. The Supreme Judicial Court reversed, holding (1) the Secretary acted within his authority under MUSA; (2) the fiduciary rule does not override common-law protections available to investors; (3) MUSA is not an impermissible delegation of legislative power; and (4) the fiduciary rule is not invalid under the doctrine of conflict preemption. View "Robinhood Financial LLC v. Secretary of the Commonwealth" on Justia Law

The Supreme Judicial Court vacated the decree and order of the superior court in this probate action, holding that there existed a genuine issue of material fact precluding the grant of partial summary judgment.The decedent's will left her entire estate to a testamentary trust for the benefit of her dog, Licorice, and any other pet she might have at the time of her death. At the time of her death, however, no pet survived the decedent. Under the terms of the trust, the trustees were required to designate a charity to receive the remainder of funds in the trustees' control after the death of all beneficiaries. At issue was whether the remainder of the decedent's estate to charity was valid despite Licorice having predeceased the decent or whether Licorice's failure to survive the decedent rendered the pet trust void. On partial summary judgment, the judge held that the pet trust provision failed because Licorice predeceased the decedent. The Supreme Judicial Court remanded the case, holding that the provisions for Licorice in the testamentary trust lapsed, leaving a genuine issue of material fact whether there was a clear intention that the charitable remainder not be conditioned on Licorice's survival of the decedent. View "In re Estate of Jablonski" on Justia Law