Justia Massachusetts Supreme Court Opinion Summaries

In 2009, the Energy Facilities Siting Board approved the petition of Brockton Power Company, LLC to build and operate a combined-cycle energy generating facility powered by natural gas and ultra-low sulfur distillate in the City of Brockton. The City, the Town of West Bridgewater, and a group of residents of the City and Town, all intervenors in the proceedings below, filed appeals of the decision. The Supreme Judicial Court affirmed the decision of the Board, holding (1) the Intervenors’ contention that the Board’s failure to apply unspecified “substantive equal protection” principles to its review of the proposed facility was without merit, as there was no requirement in the 2002 environmental justice policy to do so; (2) the Board did not abuse its discretion by relying on the National Ambient Air Quality Standards for fine particulate matter; (3) the Board did not erroneously accept Logan Airport weather data as representative of the proposed facility site; (4) the Board did not abuse its discretion in determining that Brockton Power’s evidence regarding the facility’s impact on the Town’s water supply was accurate and complete; and (5) the Board did not improperly designate delivery routes to and from the facility. View "City of Brockton v. Energy Facilities Siting Bd." on Justia Law

In 2009, the Energy Facilities Siting Board approved the petition of Brockton Power Company LLC to build and operate a combined-cycle energy generating facility powered by natural gas and ultra-low sulfur distillate in the City of Brockton. The Supreme Judicial Court affirmed the Board’s decision. In 2009, while the consolidated appeal was pending, Brockton Power submitted a project change filing (PCF) to the Board seeking approval of three changes to its project. The Board denied one of Brockton Power’s proposed changes but approved the two other project changes. Both Brockton Power and the City appealed. The Supreme Judicial Court affirmed the Board’s PCF decision in all respects, holding (1) the procedure the Board adopted to review potentially material changes to Brockton Power’s project did not constitute an abuse of its discretion; (2) the Board’s approval of Brockton Power’s proposed use of water from the City’s advanced wastewater reclamation facility for the facility’s cooling tower was not invalid; and (3) the Board did not err by concluding that the CO emissions from a gas-only plant satisfied statutory standards. View "Brockton Power Co. LLC v. Energy Facilities Siting Bd." on Justia Law

Plaintiff, Lightlab Imaging, Inc., filed this action against Defendants, a competitor of Lightlab’s and a supplier, alleging, among other causes of action, breach of contract and the covenant of good faith and fair dealing and misappropriation of trade secrets and confidential information. The trial of this action was conducted in multiple phases. The jury returned a verdict in favor of LightLab on issues of liability. At the damages phase, the parties stipulated that LightLab was entitled to nonlost profits damages in the amount of $200,000. Lastly, the trial judge awarded LightLab permanent injunctive relief for trade secrets the jury found had been misappropriated but denied permanent injunctive relief for protection against future appropriation of Lightlab’s trade secrets. The Supreme Judicial Court affirmed but ordered the inclusion of the declaration sought by LightLab, holding (1) the trial judge did not abuse her discretion in excluding opinion testimony from LightLab’s expert economist on the question of certain future lost profits; (2) the trial judge did not err in declining to issue permanent injunctions to protect Lightlab’s trade secrets; and (3) Lightlab was entitled to a declaration of its contract rights that mirrored the language of the order for summary judgment concerning contract formation. View "Lightlab Imaging, Inc. v. Axsun Techs., Inc." on Justia Law

The City of Quincy (Quincy) served as trustee of the Adams Temple and School Fund and the Charles Francis Adams Fund (together, the Funds) through two boards. The Woodward School for Girls, Inc. (Woodward) has been the sole income beneficiary of the Funds since 1953. In 2007, Woodward filed suit against Quincy seeking an accounting and asserting that Quincy committed a breach of its fiduciary duties in several respects. A probate and family court judge concluded that Quincy committed a breach of its fiduciary duties by failing to invest in growth securities and failing to heed certain investment advice, removed Quincy as trustee, and ordered Quincy to pay a nearly $3 million judgment. The Supreme Judicial Court affirmed the judgment as to liability, reversed with respect to the calculation of damages on the unrealized gains, and remanded, holding (1) Woodward’s claims were not barred on the grounds of sovereign immunity, the Massachusetts Tort Claims Act, or laches; (2) the judgment against Quincy for committing a breach of its fiduciary duties to the Funds was proper; (3) the award of damages was erroneous in the calculation of unrealized gains on the investment portfolio; and (4) the judge did not err in including prejudgment interest. View "Woodward School for Girls, Inc. v. City of Quincy" on Justia Law

Plaintiff filed a complaint in federal court against the Trustees of the Boston Public Library and a library employee alleging that he was denied entrance to the Boston Public Library in violation of his civil rights. The district court denied Plaintiff’s motion seeking disqualification of the Boston Law Department as counsel for Defendants, concluding that the Trustees constitute a municipal entity that oversees the Library as a department of the City of Boston. Plaintiff subsequently filed this action in the county court seeking a judgment declaring that the Trustees and the City “are two separate, independent legal entities,” and that the Law Department may not provide legal representation to the Trustees or Library employees. A single justice of the Supreme Judicial Court dismissed the complaint and denied postjudgment relief. The Supreme Judicial Court affirmed, holding that because the complaint in this case dealt with the same controversy that existed between the parties in the federal litigation, it did not present a proper occasion for declaratory relief. View "Lu v. City of Boston" on Justia Law

Defendants were charged with firearms violations. Defendants filed motions to suppress, which the municipal court allowed. The Commonwealth appealed, but its notice of appeal was filed late in the trial court. The Commonwealth applied to a single justice of the Supreme Judicial Court for leave to appeal, but that application was also filed late. A single justice allowed the application. The Appeals Court dismissed the appeal, concluding that it lacked jurisdiction to hear the interlocutory appeal because the Commonwealth’s notice of appeal had not been timely filed. The Supreme Judicial Court granted the Commonwealth’s request for further review and (1) affirmed the order allowing the motion to suppress; and (2) set out a new framework that will apply henceforth to the manner in which the single justices of the Court should apply the procedural rules governing the timeliness of interlocutory appeals of orders on motions to suppress. View "Commonwealth v. Jordan" on Justia Law

The Lexington school district superintendent dismissed Mark Zagaeski, a Lexington high school teacher, from his position for conduct unbecoming a teacher. Zagaeski timely filed an appeal from the school district’s dismissal decision, which resulted in arbitration proceedings. The arbitrator (1) concluded that the school district carried its burden to show facts amounting to conduct unbecoming a teacher but that Zagaeski’s conduct only “nominally” constituted a basis for dismissal; and (2) reinstated Zagaeski as a teacher on the basis of “the best interests of the pupils.” The superior court confirmed the arbitrator’s award. The Supreme Judicial Court reversed the decision of the superior court judge and vacated the arbitration award, holding that, under the facts of this case, the arbitrator exceeded the scope of his authority by awarding Zagaeski's reinstatement. View "Sch. Comm. of Lexington v. Zagaeski" on Justia Law

Plaintiff, the former president and chief operating officer of PortfolioScope, Inc., brought suit against Portfolio and two individual defendants alleging, among other claims, breach of contract, violation of Mass. Gen. Laws ch. 93A, tortious interference with Plaintiff’s contractual rights, and fraudulent transfers pursuant to the Uniform Fraudulent Transfer Act. After a bench trial, the judge rendered judgment in favor of Plaintiff. Defendants argued on appeal that the judge erred in her interpretation of an agreement and an amendment, as well as in her analysis of secured transaction principles, and that the errors affected the entire disposition of the case. The Supreme Judicial Court affirmed the judgment of the superior court in almost all respects, holding that any error in the judge’s interpretation of the amendment affected only Plaintiff’s claim for conversion. View "Weiler v. PortfolioScope, Inc." on Justia Law

Law enforcement officers stopped the vehicle Defendant was driving and placed Defendant under arrest on outstanding arrest warrants. The officers proceeded to pat frisk Defendant’s outer clothing and opened a container found on Defendant. Before transporting Defendant to the station for booking, an officer entered Defendant’s vehicle to retrieve its keys and saw an unlabeled container in plain view. The officer seized the pills contained in the container. Thereafter, Defendant was charged with illegal possession of methadone. Defendant moved to suppress the evidence seized as a result of his arrest on the outstanding warrants. The district court denied the motion, and the Appeals Court affirmed. The Supreme Judicial Court reversed the denial of Defendant’s motion to suppress, vacated Defendant’s conviction, and remanded for a new trial, holding that, under the circumstances of this case, the police exceeded the lawful scope of a search incident to arrest, an inventory search, and a seizure under the plain view doctrine. View "Commonwealth v. White" on Justia Law

The Sex Offender Registry Board notified Petitioner that it had preliminarily classified him as a level three sex offender. Petitioner requested a hearing. After the hearing had been completed but before the hearing examiner had rendered a decision, a successor examiner was appointed. The successor examiner then issued his decision classifying Petitioner as a level three offender. The superior court affirmed the Board’s decision. Petitioner sought an order directing the Board to produce a transcript of his classification hearing under 803 Code Mass. Regs. 4.22(4), which directs the Board to provide a successor hearing examiner and the parties with a copy of the transcript where the successor examiner is appointed after the presentation of evidence is complete and the record closed. Despite this requirement, no copy of the classification transcript was ever provided to Petitioner. Petitioner’s request was denied. Petitioner then filed a mandamus petition in the county court seeking to compel the Board to provide a copy of the hearing transcript. A single justice denied the motion. The Supreme Court vacated the judgment of the single justice and remanded the case to the county court where an order shall enter directing the Board to produce a copy of the transcript. View "Doe v. Sex Offender Registry Bd." on Justia Law