Justia Massachusetts Supreme Court Opinion Summaries

The Service Employees International Union, Local 509 (Union) filed a complaint seeking a declaratory judgment that the Department of Mental Health (DMH) violated the Massachusetts privatization statute by entering into contracts with private entities without adhering to the requirements set forth in Mass. Gen. Laws ch. 7, 52-55. The superior court judge allowed DMH’s motion for judgment on the pleadings, which she treated as a motion to dismiss for lack of subject matter jurisdiction, determining that the Union lacked both direct and associational standing to pursue its claim and, additionally, that the superior court lacked jurisdiction because the Union failed to join necessary parties to the action. The Supreme Judicial Court vacated and set aside the judgment of dismissal, holding (1) the judge did not err in dismissing the complaint on the basis of its failure to name all necessary parties; but (2) the Union had direct standing to seek a declaratory judgment that would invalidate the contracts at issue. Remanded for the limited purpose of allowing the Union to seek leave to amend its complaint by adding all necessary parties. View "Serv. Employees Int’l Union, Local 509 v. Dep’t Mental Health" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree and armed robbery. Defendant’s convictions were affirmed on direct appeal. Defendant subsequently sought postconviction relief in both state and federal courts, without success. Defendant’s later motion for scientific testing of a jacket purportedly worn by Defendant during the killing was granted. The jacket was retested and screened negative for the presence of the victim’s blood. On the basis of the new test results, Defendant filed a motion for a new trial. The motion judge granted the motion, concluding that the jacket was a key piece of corroborative evidence against Defendant and that the newly available evidence arising from the retesting of the jacket cast real doubt on the justice of Defendant’s conviction. The Supreme Judicial Court affirmed the judgment granting Defendant’s motion for a new trial, holding that the motion judge did not abuse her discretion in ruling that physical evidence arising from the jacket served as a “real factor” in the jury’s deliberations such that the new test results “cast real doubt on the justice of the defendant’s conviction.” View "Commonwealth v. Sullivan" on Justia Law

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