Justia Massachusetts Supreme Court Opinion Summaries

Plaintiffs, two motor vehicle dealers and an organization that represents the interests of new automobile and truck franchised dealerships in the state, filed this action against Tesla Motors, Inc., an automobile manufacturer, and Tesla Motors MA, Inc., its Massachusetts subsidiary, alleging violations of Mass. Gen. Laws ch. 93B and conspiracy to violate chapter 93B. The superior court dismissed Plaintiffs’ complaint, concluding that Plaintiffs lacked standing to maintain the action because they were not affiliated dealers of Tesla or Tesla MA. At issue before the Supreme Judicial Court was whether the 2002 amendments to chapter 93B broadened the scope of standing under the statute since the Court’s 1985 decision in Beard Motors, Inc. v. Toyota Motor Distribs., Inc. such that Massachusetts motor vehicle dealers now have standing to maintain an action for an alleged violation of the statute against unaffiliated motor vehicle manufacturers or distributors. The Court affirmed, holding that chapter 93B does not confer standing on a motor vehicle dealer to maintain an action for violation of the statute against a manufacturer with which the dealer is not affiliated. View "Mass. State Auto. Dealers Ass’n, Inc. v. Tesla Motors MA, Inc." on Justia Law

Mother and Father were the divorced parents of four minor children. Each of the parties filed contempt complaints alleging that the other had violated various terms of the divorce judgment. The judge issued an order requiring a parent coordinator to hear the parties’ disputes regarding custody and visitation before the parties could file any action regarding those disputes in court. The order also granted the parent coordinator authority to make binding decisions on matters of custody and visitation. Mother appealed. The Supreme Judicial Court vacated the order appointing the parent coordinator, holding (1) the judge exceeded the bounds of of inherent judicial authority in appointing, without all parties’ approval, the parent coordinator under the facts of this case; and (2) the breadth of authority vested in the parent coordinator constituted an impermissible delegation of judicial decision-making authority. View "Bower v. Bournay-Bower" on Justia Law

In 1997, Defendant pleaded guilty to a drug-related offense. Defendant was released in 1999 after completing his sentence on that conviction. In 2003, Defendant pleaded guilty to firearm-related offenses. In 2005, while he was incarcerated for his 2003 convictions, Defendant moved to withdraw his guilty plea for the 1997 offense. The motion was allowed, and the 1997 offense was eventually vacated. In 2011, while still incarcerated. Defendant filed a motion seeking credit for the time he had served on the vacated 1997 conviction against the sentences that he was serving on the 2003 convictions. The superior court denied Defendant’s motion, but the Appeals Court granted reversed and granted relief. The Supreme Judicial Court affirmed the superior court’s order denying Defendant’s motion for credit, holding (1) credit for time served on a vacated conviction cannot be applied against time to be served on new and unrelated sentences; and (2) moreover, allowing credit in this fashion implicates the prohibition against banking time. View "Commonwealth v. Holmes" on Justia Law

A school librarian having professional teacher status was suspended for conduct deemed to be unbecoming a teacher. An arbitrator considered the merits of the suspension. Applying a “just cause” standard, the arbitrator overturned the suspension, concluding that the school district failed to meet its burden of proof. A superior court judge confirmed the arbitrator’s award. The Supreme Judicial Court affirmed, holding that the arbitrator did not exceed his authority by reviewing the merits of the librarian’s twenty-day suspension and concluding that the school district had not met its burden of proving the alleged just cause for the suspension. View "Superintendent-Dir. of Assabet Valley Reg’l Sch. Dist. v. Speicher" on Justia Law

After a jury trial, Defendant was convicted on one indictment alleging forcible rape of a child under sixteen years of age and two indictments alleging indecent assault and battery of a child under fourteen years of age. The appeals court affirmed. Defendant appealed, arguing, among other things, that the judge erred in allowing the prosecutor on cross-examination to elicit expert testimony that both explicitly and implicitly vouched for the credibility of the victim witness regarding her allegations of sexual abuse. The Supreme Judicial Court vacated Defendant’s convictions and remanded for a new trial, holding that the trial court improperly admitted testimony during cross-examination of the victim’s therapist that implicitly vouched for the credibility of the victim, and the error was prejudicial. View "Commonwealth v. Quinn" on Justia Law

Defendant was convicted of murder in the first degree on the theories of premeditation and extreme atrocity or cruelty. Defendant’s defense was that a third party killed the victim while Defendant was unconscious due to severe intoxication. The Supreme Judicial Court affirmed Defendant’s conviction, holding (1) any prejudice in the admission into evidence of recorded telephone calls made on the day of the murder between Defendant and his girlfriend was cured by the judge; (2) the admission of a medical record showing that Defendant tested negative for any drugs was error, but Defendant suffered no risk of a miscarriage of justice; (3) counsel did not provide ineffective assistance; (4) the trial judge did not err in instructing the jury that there is no “legal limit” of intoxication for any purposes other than determining whether one is guilty of operating a motor vehicle while under the influence of alcohol; and (5) Defendant’s claim that his right to a public trial during jury empaneled was violated was waived. View "Commonwealth v. Wall" on Justia Law

After a jury trial, Defendant was convicted of attempted kidnapping and of accosting or annoying a person of the opposite sex. The Appeals Court reversed the judgment on the indictment charging accosting or annoying a person of the opposite sex, concluding that because the Commonwealth failed to demonstrate that Defendant’s conduct involved “sexually explicit language or acts,” the Commonwealth did not meet its burden of proving that Defendant’s conduct was “offensive.” The Supreme Judicial affirmed the judgment of conviction on the indictment charging accosting or annoying a person of the opposite sex, holding (1) the jury properly could have found the elements of accosting or annoying a person of the opposite sex beyond a reasonable doubt; and (2) Defendant’s counsel provided effective assistance pertaining to his conviction of accosting or annoying a person of the opposite sex. View "Commonwealth v. Sullivan" on Justia Law

After a jury trial, Defendant was convicted of aggravated kidnapping, aggravated rape, armed robbery, and related offenses. On appeal, Defendant argued that the prosecutor’s several references to his initial invocation of his right to remain silent violated his constitutional due process rights. The Appeals Court affirmed Defendant’s convictions. The Supreme Judicial Court affirmed, holding (1) the prosecutor’s references to Defendant’s invocation of his rights as set forth in Miranda v. Arizona at trial constituted error; but (2) under the circumstances of this case, the improper references did not raise a substantial risk of a miscarriage of justice. View "Commonwealth v. Letkowski" on Justia Law

Kenneth Wynne and Allison Wynne owned and operated Wynne Fine Art, which accepted art works from creditor artists. After the Wynnes filed for bankruptcy, the trustee of the bankruptcy estates moved to sell the art works. The creditor artists commenced an adversary proceeding against the bankruptcy estate seeking a declaration that the art works were held in trust under the Massachusetts fine art consignment statute, Mass. Gen. Laws, ch. 104A, 2(b), and therefore were not the property of the bankruptcy estates. The trustee counterclaimed seeking a declaration that chapter 104A was inapplicable because when the creditor artists delivered their work to the gallery they did not provide a written statement describing the art work as required by chapter 104A, section 2(b). The United States Bankruptcy Court for the District of Massachusetts certified a question of law to the Supreme Judicial Court concerning the effect of a consignor’s failure to deliver a written statement pursuant to chapter 104A, section 2(b). The Supreme Judicial Court answered that a written statement of delivery is not a prerequisite for the formation of a consignment under chapter 104A. View "Plumb v. Casey" on Justia Law

At issue in this case was a performance bond issued by Stanley Black and Decker, Inc. to secure the obligation of an environmental consulting company to perform environmental remediation of contaminated property, a portion of which was owned by Stanley. A.J. Properties, LLC commenced the underlying action against Stanley alleging that it had been assigned the right to recover all funds paid to Stanley under the performance bond. Specifically, A.J. Properties argued that Stanley had assigned the rights to payment when it assigned a mortgage on the property to the Wyman-Gordon Company, which assigned the mortgage to A.J. Properties. A federal district court judge determined that A.J. Properties was entitled to the amounts paid to Stanley under the rule of Quaranto v. Silverman. Stanley appealed, and the court of appeals recommended certification of a question of law to the First Circuit. The First Circuit answered the question as follows: “Where a mortgage and a surety agreement secured an obligation, and both the mortgagor and the surety committed a breach of that obligation prior to a written assignment of the mortgage, the assignee does not necessarily acquire the right against the surety’s receiver for the surety’s breach of its obligation.” View "A.J. Props., LLC v. Stanley Black & Decker, Inc." on Justia Law