Justia Massachusetts Supreme Court Opinion Summaries

The Commonwealth sought to civilly commit a prisoner, previously convicted of a sexual offense, as a "sexually dangerous person" (SDP) under Massachusetts law. The process required expert testimony to establish probable cause and qualified examiners to determine if the case should proceed to trial. The plaintiff, George Mackie, was initially adjudicated as an SDP based on expert reports and testimony, but this decision was later vacated on appeal due to prejudicial error.Mackie then filed separate civil actions against Dr. Katrin Rouse-Weir, a probable cause expert, and Dr. Robert Joss, a qualified examiner, alleging they submitted false reports and testimony. Both defendants moved to dismiss the complaints, claiming immunity. Superior Court judges granted the motions, concluding that the defendants were entitled to absolute quasi-judicial immunity. Mackie appealed these decisions.The Appeals Court reversed the dismissals, ruling that the experts were entitled only to qualified immunity, not absolute quasi-judicial immunity. The Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court held that qualified examiners like Joss are entitled to absolute quasi-judicial immunity due to their essential and independent role in the judicial process. The court also concluded that probable cause experts like Rouse-Weir are protected by the litigation privilege, which shields them from liability for their statements made during judicial proceedings. Consequently, the court affirmed the Superior Court judgments dismissing Mackie's complaints against both experts. View "Mackie v. Rouse-Weir" on Justia Law

The defendant was convicted of second-degree murder for the killing of Paul Finegan at a backyard birthday party in Springfield. The defendant arrived at the party, where the victim, who was uninvited, became upset upon seeing him. After a brief argument, the defendant shot the victim in the head and fled the scene. The victim was unarmed, and the defendant did not testify at trial. The defense argued that the eyewitnesses were not credible and had been pressured by the police.The case was initially tried in the Superior Court, where the defendant was found guilty of second-degree murder. The defendant filed a motion for a new trial, arguing that a voir dire question asked by the prosecutor during jury selection was improper and deprived him of an impartial jury. The trial judge denied the motion, and the Appeals Court affirmed the conviction and the denial of the motion for a new trial.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the prosecutor's voir dire question, which asked prospective jurors if they could convict the defendant based on eyewitness testimony without forensic evidence, was improper. However, the court concluded that this error did not create a substantial risk of a miscarriage of justice. The court noted that the evidence against the defendant was overwhelming, and the jury had been properly instructed on the burden of proof and the evaluation of eyewitness testimony. The court affirmed the defendant's conviction and the order denying his motion for a new trial. View "Commonwealth v. Montgomery" on Justia Law

A Braintree tobacco compliance officer observed an open container of Jazz brand "Black & Mild" cigars on display behind the cash register of a convenience store. The Board of Health of Braintree found that the store violated state and local tobacco laws by offering a flavored tobacco product for sale and imposed a $1,000 fine. The store argued that it did not intend to sell the product and that its point-of-sale system would have prevented the sale. The store also contended that the board acted outside its authority in imposing the fine and that the proceedings were procedurally defective.The Superior Court reviewed the case and upheld the board's decision, finding substantial evidence to support the board's conclusion that the store offered the cigars for sale. The court also determined that the board had the authority to impose the fine administratively and that no procedural irregularities fatally marred the board's actions. The store appealed the decision.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the Superior Court's judgment. The court held that the store's placement and display of the cigars supported the board's finding that the product was being offered for sale. The court also concluded that the legislative and regulatory scheme governing the sale of tobacco products in Massachusetts permits local boards of health to enforce the regulations and impose mandatory penalties. The court found no procedural deficiencies that would invalidate the board's actions. View "Cumberland Farms, Inc. v. Board of Health of Braintree" on Justia Law

The case involves a dispute between partners in a limited partnership formed to develop and operate an affordable housing project in Boston. The financing and structure of the project were driven by the Low Income Housing Tax Credit (LIHTC) program, which incentivizes private investment in affordable housing through tax credits. The partnership agreement included a right of first refusal (ROR) for the nonprofit general partner to purchase the property at a below-market price after the compliance period.In the Superior Court, the judge ruled on cross motions for summary judgment, concluding that the investor limited partner, AMTAX, did not have a consent right over a sale to the nonprofit general partner under the ROR agreement. However, the judge also ruled that the purchase price under the ROR agreement must include the limited partners' exit tax liability. The judge dismissed the remaining claims and counterclaims due to lack of evidentiary support or as a consequence of these rulings.The Supreme Judicial Court of Massachusetts reviewed the case. The court affirmed the lower court's decision, holding that AMTAX's consent was not required for the preliminary steps leading to a sale under the ROR agreement. The court also held that the limited partners' exit taxes were "attributable to" the sale of the property and must be included in the purchase price. The court found that the notice of consent rights recorded by AMTAX was accurate and did not constitute slander of title or tortious interference. Consequently, the plaintiffs' claims for breach of contract, breach of the implied covenant of good faith and fair dealing, tortious interference, slander of title, and violation of G. L. c. 93A were dismissed. The judgment was affirmed. View "Tenants' Development Corporation v. Amtax Holdings 227, LLC" on Justia Law

The case involves a dispute over the construction of a substation by Park City Wind LLC (PCW) that will connect an offshore wind farm to the New England electric grid. Jacqueline Johnson, the petitioner, lives near the proposed substation site and raised concerns about the noise impact from the substation, which includes loud step-up transformers. PCW presented expert testimony and reports to the Energy Facilities Siting Board (the board) indicating that design features would mitigate the noise impact, keeping it within the allowable increase of ten A-weighted decibels (dBA) set by the Department of Environmental Protection (DEP).The board approved PCW's petition to construct the substation, subject to several conditions, including preconstruction and postconstruction reviews to ensure the noise levels at Johnson's home would not exceed an eight dBA increase. Johnson was allowed to participate fully in the administrative process, including discovery, briefing, and cross-examination of PCW's experts. The board required PCW to confirm that the predicted noise levels would not be exceeded once the equipment specifications were known and to implement additional noise mitigation measures if necessary.The Supreme Judicial Court of Massachusetts reviewed the case. Johnson argued that the board's decision was not supported by substantial evidence because it relied on aggressive sound level design specifications for yet-to-be-manufactured equipment. The court concluded that Johnson failed to meet the heavy burden required to overturn the board's decision, which was supported by substantial evidence, including expert testimony and industry-standard sound modeling. The court also found that the board's conditional approval, requiring preconstruction and postconstruction compliance filings, was lawful and within the board's statutory authority. The court affirmed the board's decision. View "Johnson v. Energy Facilities Siting Board" on Justia Law

The case involves the Massachusetts Bay Transportation Authority (MBTA) Communities Act, which mandates that cities and towns with local access to MBTA services adopt zoning laws to provide at least one district of multifamily housing "as of right" near their MBTA facilities. The town of Milton, which has four MBTA stations, voted down a proposed zoning scheme to comply with the act. The Attorney General then sued the town to enforce the act.The Supreme Judicial Court for the county of Suffolk reviewed the case. The town initially took steps to comply with the act, including hiring a consultant and submitting an action plan to the Executive Office of Housing and Livable Communities (HLC). However, a town-wide referendum ultimately rejected the proposed zoning bylaw. The Attorney General filed a complaint seeking declaratory and injunctive relief to enforce compliance with the act.The Supreme Judicial Court of Massachusetts held that the MBTA Communities Act is constitutional and that the Attorney General has the authority to enforce it. However, the court found that the HLC did not comply with the Administrative Procedure Act (APA) when promulgating the guidelines, rendering them ineffective. The court granted declaratory relief in part and dismissed the remaining claims, directing the single justice to enter a declaratory judgment consistent with the opinion. View "Attorney General v. Town of Milton" on Justia Law

In July 2019, the defendant was charged with one count of possession of child pornography. While at a supermarket, a mother observed the defendant pointing his cell phone at an unusual angle towards her and her daughters. The defendant denied taking photos and showed the mother his phone, which contained several images of clothed women from the waist down. The mother reported the incident to the police. Officer Columbus, who was present at the store, investigated and found numerous images of clothed women on the defendant's phone. Upon further inspection, with the defendant's consent, Columbus discovered images she believed to be child pornography. The defendant admitted to possessing child pornography but claimed he took screenshots to report them to website administrators, though he had not done so.The defendant was found guilty in a bench trial in the District Court and sentenced to six months in a house of correction, suspended for two years. He appealed, arguing that the trial judge erred by allowing a lay witness to testify about the technology used to extract data from his cell phone, which he contended required expert testimony.The Supreme Judicial Court of Massachusetts reviewed the case. The court agreed that the trial judge abused his discretion by allowing some of the contested testimony from Officer McLaughlin, who explained the Cellebrite system used to extract data from the defendant's phone. However, the court concluded that the error was nonprejudicial. The court found that the evidence against the defendant was overwhelming, including testimony from multiple officers and the defendant's own admission. Additionally, the images were properly admitted through McLaughlin's lay testimony. Therefore, the court affirmed the defendant's conviction. View "Commonwealth v. Cronin" on Justia Law

The plaintiff, Steven Luppold, filed a medical malpractice lawsuit after an above-the-knee amputation of his left leg. He alleged that the negligence of three healthcare providers—Susan Hanlon, a registered nurse; Charles Loucraft, a physician assistant; and Carlos Flores, a nurse practitioner—led to his injury. Luppold visited the emergency department at Lowell General Hospital twice in March 2015, complaining of severe foot pain and discoloration. Despite these symptoms, he was discharged without proper diagnosis or treatment, leading to the eventual amputation.In the Superior Court, a jury awarded Luppold $20 million in damages, finding Hanlon, Loucraft, and Flores negligent. Hanlon moved for judgment notwithstanding the verdict, to set aside the verdict, or for remittitur, arguing that the trial judge erred in not allowing cross-examination about a high-low settlement agreement between Loucraft and Flores, and that the jury instructions on factual causation were incorrect. The trial judge denied her motion, and Hanlon appealed.The Supreme Judicial Court of Massachusetts reviewed the case. The court found no abuse of discretion in the trial judge's decision to exclude cross-examination about the high-low settlement agreement, as Hanlon failed to demonstrate how the agreement caused bias or changed testimony. The court also upheld the jury instructions on factual causation, determining that they correctly conveyed the "but-for" causation standard required by law. Additionally, the court rejected Hanlon's argument that she was entitled to judgment notwithstanding the verdict, finding sufficient evidence that her actions fell below the standard of care and contributed to Luppold's injury.Finally, the court affirmed the assessment of prejudgment interest on the entire damages award, including future pain and suffering, as required by Massachusetts law. The judgment and the order denying Hanlon's posttrial motions were affirmed. View "Luppold v. Hanlon" on Justia Law

The plaintiff filed a complaint in the Land Court regarding a property in Duxbury, claiming ownership following a foreclosure sale. The defendants, who had executed a mortgage in favor of the plaintiff's predecessor, refused to vacate the property. The Land Court judge ruled in favor of the plaintiff, declaring them the lawful owner. The defendants appealed this decision.Subsequently, the plaintiff filed a summary process complaint in the Housing Court to gain possession of the property and requested use and occupancy payments from the defendants during the litigation. The Housing Court judge granted this request but stayed the proceedings pending the appeal of the Land Court judgment. The defendants sought interlocutory relief from a single justice of the Appeals Court, who vacated the Housing Court's order, stating that the Housing Court judge had not determined ownership.The plaintiff renewed their motion in the Housing Court, which was again granted, with the judge explicitly relying on the Land Court's judgment under the doctrine of res judicata. The defendants again sought relief from the single justice, who vacated the order, arguing that the Housing Court judge's reliance on the appealed Land Court judgment was improper. The plaintiff was granted leave to appeal to a full panel of the Appeals Court, and the Supreme Judicial Court transferred the case on its own motion.The Supreme Judicial Court held that a judge hearing a summary process action for possession may rely on a final judgment of the Land Court regarding ownership, even if an appeal is pending. The court confirmed that the Land Court's judgment had preclusive effect, allowing the Housing Court judge to order interim use and occupancy payments. The order of the single justice was reversed, and the defendants' petition for relief was denied. View "TJR Services LLC v. Hutchinson" on Justia Law

In 2013, an eleven-year-old juvenile was charged with rape of a child by force and assault and battery on a child with substantial injury after allegedly biting his four-year-old cousin's penis. The rape charge was dismissed, and the juvenile was placed on one year of pretrial probation for the reduced charge of simple assault and battery. The juvenile completed probation without incident, and the charge was dismissed. In 2023, the now twenty-two-year-old juvenile, with no other record, petitioned to expunge his record under a statute allowing expungement if the offense is no longer a crime.The Juvenile Court denied the expungement petition. The court found that the offenses of rape of a child by force and assault and battery remain criminal acts, regardless of the age of the perpetrator, and thus do not qualify for expungement under the statute. The court also noted that the juvenile's records were ineligible for time-based expungement due to the serious nature of the offenses.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the Juvenile Court's decision. The court held that the 2018 legislative change, which excluded children under twelve from the Juvenile Court's jurisdiction, did not alter the definition of what constitutes a "crime" for the purposes of expungement under the statute. The court concluded that the relevant inquiry is whether the conduct itself has been decriminalized, not whether the individual can be prosecuted due to age. Since the conduct in question remains criminal, the juvenile's records do not qualify for expungement. View "Commonwealth v. Ambrose A." on Justia Law