Justia Massachusetts Supreme Court Opinion Summaries

Defendant was convicted of two indictments alleging receipt of stolen property. Defendant appealed, arguing that the judge erred in denying his motion to suppress because the arrest warrants leading to the search of an apartment where the stolen property was discovered did not authorize the police to enter the apartment. Specifically, Defendant argued that the police did not have a “reasonable belief” that Defendant was present in the apartment, and therefore, the subsequent seizure of the stolen property was the fruit of this unconstitutional entry. The Supreme Court vacated the convictions and remanded, holding (1) a “reasonable belief” requires more than was known at the time of entry in this case; and (2) therefore, the entry was unconstitutional, and the observation and subsequent seizure of the stolen property allegedly received by Defendant should have been suppressed as the fruit of the illegal entry. View "Commonwealth v. Gentile" on Justia Law

When Rita Licata was transferred to a nursing facility operated by Defendant Rita’s son Salvatore signed an agreement with the facility to arbitrate disputes arising from Rita’s stay at the facility. Salvatore signed the agreement in the space provided for the resident’s “authorized representative.” Rita suffered personal injuries at the nursing facility resulting in her death. Salvator filed a complaint as administrator of Rita’s estate against Defendant for, inter alia, wrongful death and negligence. Defendant filed a motion to dismiss the complaint and to compel arbitration. The motion judge denied the motion, concluding that Salvatore lacked authority to execute the arbitration agreement on Rita’s behalf. The Supreme Court affirmed, holding (1) Salvatore lacked authority to execute the agreement on Rita’s behalf; and (2) the arbitration agreement did not otherwise bind Rita’s estate. View "Licata v. GGNSC Malden Dexter LLC" on Justia Law

Barbara Johnson, in her capacity as her husband Dalton’s health care agent, signed an agreement with a nursing facility to arbitrate disputes arising from Dalton’s stay at the facility. While a resident of the facility, Dalton suffered burns and later died. The administrators of Dalton’s estate, filed a complaint against nursing home defendants and others, arguing that Barbara, as Dalton’s health care agent, did not have the authority to execute the arbitration agreement on his behalf. A superior court judge entered an order compelling mediation or arbitration. The Supreme Court vacated the order of the superior court, holding that a health care agent’s decision to enter into an arbitration agreement is not a health care decision under the health care proxy statute, and therefore, an agreement to arbitrate all claims arising out of a principal’s stay in a nursing facility does not bind the principal where the agreement was entered into solely by a health care agent under the authority of a health care proxy. View "Johnson v. Kindred Healthcare, Inc." on Justia Law

Defendant was incarcerated for rape of a child when the Commonwealth filed a petition to have him declared a sexually dangerous person (SDP). Several months after the conclusion of a jury-waived trial, a superior court judge issued a decision concluding that Defendant was an SDP and ordering him committed to a treatment center. Defendant appealed, arguing, among other things, that the trial judge erred in failing to issue a decision within thirty days of the end of trial in accordance with Commonwealth v. Blake. The court of appeals affirmed. The Supreme Court affirmed, holding that although the trial judge’s decision was not issued within thirty days as required by Blake, neither dismissal of the Commonwealth’s petition nor a new trial was warranted under the circumstances. View "Commonwealth v. Pariseau" on Justia Law

After a second jury trial, Defendant was convicted of rape of a child. Prior to trial, Defendant moved to compel the production of psychological records of the complainant in the custody of the complainant’s psychologist. The motion judge denied the motion, concluding that statements by the complainant to her psychologist concerning the alleged assault, without more, did not meet the threshold requirements of Commonwealth v. Dwyer and Commonwealth v. Lampron. The court of appeals affirmed. The Supreme Court remanded the case to the superior court, holding that a summons for the production of the psychologist’s records related to the complainant’s sexual assault should have issued in this case. Remanded. View "Commonwealth v. Labroad" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of extreme atrocity or cruelty. The Supreme Court reversed and remanded for a new trial. Defendant was tried again and was again convicted of murder in the first degree on a theory of extreme atrocity or cruelty. The Supreme Court vacated the murder conviction and remanded for entry of a verdict of murder in the second degree, holding that Defendant’s mental illness and impaired mental condition drove her behavior and materially affected the fairness of a conviction of murder in the first degree on a theory of extreme atrocity or cruelty and that the unusual circumstances of this case made a verdict of murder in the second degree more consonant with justice. View "Commonwealth v. Berry" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Court affirmed Defendant’s convictions and the denial of his motion for a new trial, holding (1) Defendant’s Sixth Amendment right to a public trial was not violated when the trial judge ordered that, before entering the court room, each spectator must sign in and give a source of identification to the court officer posted outside the court room; (2) the trial judge did not err by admitting into evidence grand jury testimony of a prosecution witness; (3) the admission of certain hearsay did not create a substantial likelihood of a miscarriage of justice; and (4) the trial judge did not violate Defendant’s right to be tried by an impartial jury by failing to conduct a voir dire of all the jurors after one juror expressed concern that Defendant had access to the juror’s address in the juror’s confidential questionnaire. View "Commonwealth v. Maldonado" on Justia Law

Following a jury trial nearly three years after his initial arraignment, Defendant was convicted of disorderly conduct and assault by means of a dangerous weapon. The Supreme Court reversed Defendant’s convictions and dismissed the complaints against him, holding (1) Defendant was denied a speedy trial, and any failures by his trial counsel to perfect that claim constituted ineffective assistance of counsel; and (2) the trial judge’s order of restitution to compensate a police officer whose glasses were damaged during his interaction with Defendant was constitutional under Apprendi v. New Jersey and met the “causal connection” requirement for such awards under Commonwealth v. McIntyre. View "Commonwealth v. Denehy" on Justia Law

Defendant was convicted of first degree murder on a theory of joint venture and sentenced to life in prison. Defendant appealed, arguing, among other things, that the trial judge erred in finding that he was not a target of the investigation, and because he was a target, the Commonwealth was required to advise him of his Fifth Amendment right to avoid self-incrimination. The Supreme Court affirmed, holding (1) the evidence was sufficient to permit a jury to find Defendant guilty of murder in the first degree; (2) the trial judge did not err in determining that Defendant was not a target of the investigation at the time of his grand jury testimony, but a new prospective rule requires the Commonwealth to advise targets or potential targets of the grand jury’s investigation of their right not to incriminate themselves; and (3) Defendant was not entitled to a DiGiambattista instruction where it was not requested at trial. View "Commonwealth v. Woods" on Justia Law

The Attorney General issued four citations to Plaintiffs for failing to pay the prevailing wage to certain employees. Plaintiffs appealed the citations to the Division of Administrative Law Appeals (DALA) under Mass. Gen. Laws ch. 149, 27C(b)(4). Kimberly Fletcher, a DALA administrative magistrate, heard Plaintiffs’ appeal but resigned before DALA issued a decision on the appeal. Shelly Taylor, the chief administrative magistrate of DALA, subsequently reviewed Fletcher’s proposed decision and took over responsibility for deciding the appeal. The DALA then issued a decision on Plaintiffs’ appeal, which affirmed the fourth citation and vacated the first three. Fletcher’s and Taylor’s rationales for vacation differed, however. The superior court affirmed the DALA decision. The Supreme Court affirmed, holding (1) the superior court was correct in affirming the fourth citation; (2) the DALA chief administrative magistrate has the authority to review and approve a hearing officer’s decision in a section 27C(b)(4) appeal before a final opinion issues; and (3) under these circumstances, Taylor’s actions in completing the section 27C(b)(4) hearing and administrative decision process were appropriate. View "Lighthouse Masonry, Inc. v. Div. of Admin. Law Appeals" on Justia Law