Justia Massachusetts Supreme Court Opinion Summaries

Jeff Stacy, a lineman for Unitil Corporation, continued working during the COVID-19 pandemic as his job was classified as an essential service. Despite the Governor's orders to shut down nonessential businesses, Stacy worked closely with colleagues, which led to his exposure to the virus. In February 2021, after working overtime during snowstorms, Stacy contracted COVID-19 from a coworker, resulting in severe illness and total disability. He applied for workers' compensation benefits, which were initially denied by his employer's insurer, Travelers Indemnity Company of Connecticut.An administrative judge from the Department of Industrial Accidents held an evidentiary hearing and ruled in favor of Stacy, finding that the risk of contracting COVID-19 was inherent in his employment during the pandemic. The judge noted that Stacy's job required close physical proximity to coworkers, increasing his risk of infection. The Industrial Accident Reviewing Board affirmed the judge's decision, adopting the factual findings and concluding that the decision was supported by adequate evidence and reasoned decision-making.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the board's decision. The court held that the board's determination that the risk of contracting COVID-19 was inherent in Stacy's employment was not arbitrary or capricious. The court emphasized that Stacy's role as an essential worker, who continued to work closely with others during a time when most businesses were closed and social distancing was mandated, justified the finding that his employment posed a unique risk of infection. Thus, Stacy's claim for workers' compensation benefits was upheld. View "Stacy's Case" on Justia Law

A juvenile was found delinquent on firearm charges and guilty on a youthful offender indictment for one of the offenses. At the trial, the juvenile was nineteen years old, and the Commonwealth called his mother to testify about events that occurred when he was seventeen. The juvenile argued that the parent-child witness disqualification statute, which prohibits testimony by a parent against their minor child, should have precluded his mother's testimony even though he was no longer a minor at the time of trial. He also claimed that the trial judge made several errors in admitting other evidence and that his sentence was unlawful and unconstitutional.The juvenile was charged in a delinquency complaint with possession of a firearm without a firearm identification card, unlawful possession of a large capacity feeding device, and improper storage of a firearm. He was subsequently indicted as a youthful offender for the large capacity feeding device charge. The juvenile filed a motion to prevent the Commonwealth from calling his mother as a witness, invoking the parent-child witness disqualification statute. The motion judge denied the motion, reasoning that the statute applied only to testimony against a minor child, and the juvenile was no longer a minor.The Supreme Judicial Court of Massachusetts reviewed the case and agreed with the trial judge's interpretation that the statutory prohibition of testimony by a parent against their minor child does not apply once the child has reached the age of eighteen. The court found no prejudicial error in the admission of other evidence, although it concluded that the judge should not have admitted a detective's testimony that a firearm depicted in still images was "identical" to the firearm admitted in evidence, nor two hearsay statements. Regarding the juvenile's sentence, the court agreed that the judge erred in not issuing written findings explaining the sentence but concluded that this error did not prejudice the juvenile. The court affirmed the juvenile's delinquency and youthful offender adjudications and declined to vacate his sentence. View "Commonwealth v. Rajiv R." on Justia Law

The defendant was found guilty of first-degree murder, improper disposal of a body, and willfully misleading a police officer. The case involves the killing of a long-time friend, whose body was discovered by a passerby in a wooded area. The victim was identified through fingerprint records, and his cause of death was determined to be acute cyanide toxicity. The investigation revealed that the defendant and the victim had met on the day of the victim's death, and the defendant had given inconsistent and false statements to the police about their meeting.In the Superior Court, the defendant's pretrial motions to suppress evidence obtained from searches and his statements to the police were denied. The trial proceeded with the Commonwealth presenting evidence of the defendant's financial troubles and his purchase of cyanide. The defense argued that the defendant's confessions were not voluntary due to his medical and emotional state following a suicide attempt. The jury found the defendant guilty on all charges, and he was sentenced to life in prison for the murder conviction, with concurrent sentences for the other charges.The Supreme Judicial Court of Massachusetts reviewed the case. The defendant argued that the evidence obtained from the searches should have been suppressed due to lack of probable cause and that his statements to the police were involuntary. The court found no error in the denial of the motions to suppress, concluding that the affidavits provided sufficient probable cause and that the defendant's waivers of his Miranda rights and his statements were voluntary. The court affirmed the defendant's convictions and declined to order a new trial or reduce the conviction. View "Commonwealth v. Camuti" on Justia Law

The case involves a defendant who was convicted of multiple charges following an altercation involving a woman and three men, including the defendant and the victim. The defendant was found guilty of assault with intent to maim, mayhem, assault and battery by means of a dangerous weapon (knife) causing serious bodily injury, assault and battery by means of a dangerous weapon (shod foot), two counts of assault and battery, and misleading a police officer. The incident occurred after the defendant drove the intoxicated woman to her home, where a violent confrontation ensued with the victim.In the Superior Court, the defendant was convicted by a jury on the aforementioned charges. The defendant appealed, raising three issues: the exclusion of Adjutant evidence, the sufficiency of evidence for the conviction of misleading a police officer, and the duplicative nature of certain convictions. The Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and held that the trial judge did not abuse his discretion in excluding the Adjutant evidence related to the defendant's self-defense claim and declined to extend the Adjutant rule to defense of another. The court found insufficient evidence to support the conviction of misleading a police officer, as the defendant's simple denial did not demonstrate specific intent. The court also determined that the convictions for assault with intent to maim and assault and battery by means of a dangerous weapon causing serious bodily injury were duplicative of the mayhem conviction, and one of the assault and battery convictions was duplicative of the assault and battery by means of a dangerous weapon conviction. Consequently, the court vacated the convictions for misleading a police officer, assault with intent to maim, assault and battery by means of a dangerous weapon causing serious bodily injury, and one count of assault and battery, while affirming the remaining convictions and remanding the case for resentencing. View "Commonwealth v. Rateree" on Justia Law

The defendant was convicted of animal cruelty after witnesses observed him repeatedly punching his dog in a public park. The defendant claimed he was trying to save a groundhog his dog was attacking and that he minimized the force of his punches. The defendant appealed, arguing that the trial judge erred in excluding his expert witness's testimony about the dog's pain response and prey drive, and in refusing to instruct the jury on bona fide discipline and defense of another animal.The case was initially tried in the Newburyport Division of the District Court Department, where the jury found the defendant guilty. The defendant's postconviction motion for a new trial was denied, and he filed a timely notice of appeal. The Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court held that the trial judge did not abuse her discretion in excluding the expert testimony, as it was cumulative and would not have significantly aided the jury. The court also found that the jury instructions provided were sufficient to allow the jury to consider the defendant's arguments regarding bona fide discipline and defense of another animal. The court affirmed the conviction, concluding that there was no reversible error in the trial proceedings. View "Commonwealth v. Adams" on Justia Law

The case involves BAK Realty, LLC, and Crossing Over, Inc., which operate a sober house in a three-family dwelling in Fitchburg, Massachusetts. The sober house, located in a residential B (RB) district, houses thirteen unrelated individuals recovering from addiction. The City of Fitchburg's zoning ordinances classify the sober house as a boarding house, a use not permitted in the RB district. The plaintiffs argue that the city's zoning ordinances violate the anti-disability discrimination provision of the Zoning Act, G. L. c. 40A, § 3, fourth par., which they interpret as requiring the city to treat the sober house residents as a "family" under local zoning laws.The Superior Court judge granted partial summary judgment in favor of the plaintiffs, annulling the decision of the Fitchburg Zoning Board of Appeals (board). The judge concluded that G. L. c. 40A, § 3, required the city to treat the sober house residents the same as a family or any similar-sized group of unrelated persons, whichever is more favorable. The judge ruled that the city's zoning ordinances could not be enforced against the sober house residents.The Supreme Judicial Court of Massachusetts reviewed the case and disagreed with the Superior Court's interpretation. The court held that G. L. c. 40A, § 3, fourth par., does not preempt municipalities from defining "family" for zoning purposes. The statute requires that disabled persons in congregate living arrangements be treated the same as either families or similar-sized groups of unrelated persons, but not necessarily both. The court found that the residents of the sober house did not meet the local definition of "family" and were treated the same as any similar group of thirteen unrelated people living together. Therefore, the court reversed the judgment of the Superior Court, upholding the board's decision that the sober house was operating as a boarding house, a use not permitted in the RB district. View "BAK Realty, LLC v. City of Fitchburg" on Justia Law

The plaintiff, Lorraine Bellmar, as the personal representative of her deceased husband Harry Bellmar's estate, filed a medical malpractice and wrongful death action against Dr. Robert Moore and his medical practice. Harry Bellmar had been Dr. Moore's patient for approximately ten years, suffering from morbid obesity, hypertension, obstructive sleep apnea, and high cholesterol. In December 2006, an abnormal EKG was performed, but Dr. Moore did not order any follow-up cardiac testing over the next ten years. Harry Bellmar died in June 2016 from cardiac arrhythmia.The Superior Court granted summary judgment in favor of the defendants, concluding that the plaintiff's claim was barred by the seven-year statute of repose under G. L. c. 260, § 4, because the claim was based on the 2006 EKG, which occurred more than seven years before the filing of the lawsuit in December 2017. The Appeals Court affirmed the decision.The Supreme Judicial Court of Massachusetts reviewed the case and reversed the lower courts' decisions. The court held that the statute of repose does not shield later negligent acts if the medical malpractice claim is not predicated on acts or omissions that took place more than seven years before the filing of the claim. The court found that there were genuine issues of material fact regarding whether Dr. Moore's treatment of the decedent within the seven-year period was negligent, independent of the 2006 EKG. The case was remanded to the Superior Court for further proceedings. View "Bellmar v. Moore" on Justia Law

A Cambridge police officer observed a black Mazda sedan with an unilluminated rear license plate and initiated a traffic stop. The driver, Natnael Zemene, and two passengers were removed from the vehicle for an inventory search, which revealed a bottle of tequila and a box of ammunition. During a subsequent pat frisk, a firearm was found under Zemene's foot. Zemene admitted ownership of the firearm and was arrested.Zemene was charged with possession of ammunition without a license, carrying a firearm without a license, carrying a loaded firearm without a license, unlicensed operation of a motor vehicle, and two civil motor vehicle infractions. He was found guilty of carrying a firearm without a license but not guilty of the other charges. The trial judge denied his motion for a required finding of not guilty and sentenced him to eighteen months in a house of correction. Zemene's post-trial motions were denied, and his sentence was stayed pending appeal.The Supreme Judicial Court of Massachusetts reviewed the case. Zemene argued that retrial on the charge of carrying a firearm without a license would violate the double jeopardy clause. The court held that the relevant legal change occurred with its decision in Commonwealth v. Guardado, not the U.S. Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen. Therefore, the double jeopardy clause did not bar retrial. The court affirmed the single justice's denial of Zemene's petition for relief. View "Zemene v. Commonwealth" on Justia Law

The defendant was observed by a state trooper driving at a high speed and was stopped. During the stop, the trooper noticed the defendant making movements that suggested he might be armed. The trooper conducted a patfrisk and found a firearm in the defendant's jacket pocket. The defendant was charged with carrying a firearm without a license and other related offenses. He filed a motion to suppress the firearm and a statement he made during the stop, which was denied. The defendant was convicted and sentenced to eighteen months in a house of correction.The defendant's trial occurred after the Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen but before the Massachusetts Supreme Judicial Court's decision in Commonwealth v. Guardado. The trial court denied the defendant's posttrial motion for a required finding of not guilty, and the defendant appealed. The Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the defendant is entitled to a new trial. The court determined that the appropriate remedy for defendants convicted under G. L. c. 269, § 10 (a) after Bruen but before Guardado I is a new trial, not a required finding of not guilty. The court reasoned that the Commonwealth could not have known it needed to prove the absence of a firearms license at the time of the defendant's trial, as Guardado I had not yet been decided. The court also affirmed the denial of the defendant's motion to suppress the firearm, finding that the trooper had reasonable suspicion to conduct the patfrisk and probable cause to seize the firearm. The case was remanded for a new trial. View "Commonwealth v. Crowder" on Justia Law

Two minor sisters suffered severe harm while in the custody of the Department of Children and Families (DCF). In August 2015, the older sister, then twenty-two months old, manipulated a thermostat dial from her crib, causing the bedroom to overheat. This incident led to her permanent impairment and the death of another foster child. A lawsuit was filed in the Superior Court against several defendants, including four DCF employees, alleging that their failure to fulfill their duties caused the children's harm.The Superior Court denied the employees' motion for summary judgment, which argued they were entitled to qualified immunity. The employees appealed under the doctrine of present execution, and the Supreme Judicial Court transferred the case on its own motion.The Supreme Judicial Court concluded that the DCF employees did not violate the children's substantive due process rights, as their conduct was not the proximate cause of the harm suffered. The court held that the employees' omissions, such as failing to conduct more frequent home visits or investigate the presence of a potentially dangerous individual in the foster home, did not foreseeably lead to the children's injuries. Therefore, the employees were entitled to qualified immunity, and the Superior Court's denial of summary judgment was reversed. View "Gotay v. Creen" on Justia Law