Justia Massachusetts Supreme Court Opinion Summaries

In this case, the Supreme Judicial Court set forth a new standard for determining when substantial justice would best be served by the sealing of certain criminal records under Mass. Gen. Laws ch. 276, 100C after concluding that the stringent standard for discretionary sealing articulated nearly twenty years ago no longer achieves the proper balance of interests. Here, Defendant filed a petition to seal his criminal record pursuant to chapter 276, section 100C due to its impact on his employment opportunities. The judge denied the petition. Although Defendant attained desired relief through another process, the Supreme Judicial Court exercised its discretion to revisit the standard for discretionary sealing pursuant to chapter 276, section 100C. View "Commonwealth v. Pon" on Justia Law

After Defendant’s first three trials ended in mistrials, a fourth trial was held, and Defendant was convicted of murder in the first degree on theories of felony-murder and extreme atrocity or cruelty. Defendant appealed, raising numerous claims of error. The Supreme Court affirmed the convictions, holding (1) the trial court did not commit prejudicial error in its evidentiary rulings; (2) any error committed by the prosecutor during closing argument was not prejudicial; (3) the trial judge did not err in denying Defendant’s motion to dismiss the indictments against him; and (4) the Commonwealth engaged in egregious misconduct by issuing a press release regarding the case, but the conduct was not of sufficient significance to result in the denial of Defendant’s right to a fair trial. The Court also reinstated Defendant’s two convictions of armed robbery - the underlying felonies in the felony-murder conviction - which the trial judge had dismissed as duplicative, holding that those convictions were not duplicative where Defendant was also convicted on another theory of murder in the first degree - murder with extreme atrocity or cruelty. View "Commonwealth v. Wood" on Justia Law

Defendant was stopped by police officers while walking down the street. An officer asked for permission to search the backpack Defendant was carrying, whereupon Defendant removed the bag and handed it to the officer. The officer then removed a box designed to look like a cigarette package but which was “noticeably heavier.” At this time, Defendant changed his mind and told the officer he could not look in the bag. The officer proceeded to open the box and discovered cocaine. Defendant filed a motion to suppress the evidence seized as a result of his stop and subsequent arrest. The trial court denied the motion, and the court of appeals affirmed. Defendant was subsequently convicted of possession of cocaine with intent to distribute. Defendant appealed the denial of his motion to suppress. The Supreme Court vacated the conviction and ordered a new trial, holding (1) the investigatory stop of Defendant was supported by reasonable suspicion; but (2) there was no probable cause to make an arrest when the cigarette box was opened, and the opening of the cigarette box could not be justified as a search incident to arrest. View "Commonwealth v. Stewart" on Justia Law

Defendant was convicted of armed assault with intent to murder and unlawful possession of a firearm. Because the firearms offense for which Defendant was convicted had two applicable sentencing enhancement statutes, and the Commonwealth proved convictions of separate prior offenses for each, the judge imposed two sentences pursuant to the sentencing enhancement statutes. The Supreme Court affirmed Defendant’s convictions but remanded to the superior court with instructions that the judge vacate the sentence of one of the two sentencing enhancement counts, holding that unless the Legislature has explicitly declared its intent to permit multiple sentencing enhancements, a defendant may be sentenced under only one sentencing enhancement statute. View "Commonwealth v. Richardson" on Justia Law

In December, 2010, Carolyn Zaleski (wife) filed for divorce from Stephen Zaleski (husband) on the ground that the marriage was irretrievably broken. A judgment was ultimately entered granting a divorce nisi on that ground, and awarded rehabilitative alimony to the wife, divided the marital assets, and incorporated a stipulation of the parties regarding the custody and education of their two children. Wife appealed, challenging that portion of the judgment ordering the husband to pay rehabilitative alimony rather than general term alimony. She also challenged the judge's exclusion of the husband's bonus income from the calculation of the amount of the alimony award; the requirement that she maintain policies of term and whole life insurance as security for her obligations under the divorce judgment; and the division of marital assets, including the allocation of marital debt. Upon review, the Supreme Court concluded that the trial court did not abuse its discretion in awarding rehabilitative alimony, and that the allocation of debt and division of property between the parties was warranted by the evidence. Nonetheless, the Court remanded the case for further proceedings based on its determination that the trial court erred in not including all of the husband's income in the calculation of the amount of alimony, and that there was no basis in the judge's findings to require the wife to maintain life insurance policies as security. View "Zaleski v. Zaleski" 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 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