Justia Massachusetts Supreme Court Opinion Summaries

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The Supreme Judicial Court held that the board of registration in medicine may use a sealed criminal record as a basis for discipline but that the board is statutorily prohibited from making the contents of that record available to the public.Petitioner, a physician licensed by the board, was arrested and charged with a misdemeanor count of engaging in sexual conduct for a fee. After the board informed Petitioner that he was under investigation the court dismissed Petitioner's criminal case and Petitioner filed an application to renew his medical license. Thereafter, pursuant to Petitioner's request, a judge in the district court ordered Petitioner's criminal record sealed under Mass. Gen. Laws ch. 276, 100C. Petitioner notified the board of the sealing order and requested that his disciplinary matter be closed. When the board declined to close the matter Petitioner filed an emergency petition for writ of certiorari. The Supreme Judicial Court held that section 100C does not prohibit the board from using a record sealed under the section in its disciplinary proceedings, but it does prohibit the board from publicly disclosing any information gleaned directly from a record sealed under section 100C. View "Doe v. Board of Registration in Medicine" on Justia Law

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The Supreme Judicial Court concluded that the existing September 1, 2020 deadline for the receipt of mail-in primary election ballots is constitutional.In response to the COVID-19 pandemic, the Legislature passed an emergency law to increase voting options in the September 1 primary election and the November 3 general election. The act included the additional voting option of voting by mail. For the primary election, voters may apply for a mail-in ballot, so long as their application to vote by mail is received by August 26, and the mail-in primary election ballot is completed and received by local election officials before 8 p.m. on September 1. Plaintiffs argued that the September 1 deadline significantly interferes with the constitutional right to vote. The Supreme Court disagreed, holding that the September 1 deadline for the receipt of mail-in primary election ballots is not unconstitutional. View "Grossman v. Secretary of the Commonwealth" on Justia Law

Posted in: Election Law
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In this case involving procedures and remedies for impermissible peremptory challenges the Supreme Judicial Court adopted the language of the Federal standard for the first step of a challenge pursuant to Batson v. Kentucky, 476 U.S. 79 (1986), and retired the language of "pattern" and "likelihood" governing the first-step inquiry under Commonwealth v. Soares, 444 U.S. 881 (1979).While incarcerated, Defendant argued on appeal and in pursuing postconviction relief that the trial judge did not appropriately inquire as to whether the prosecutor unconstitutionally struck African-American men from the jury. The Appeals Court determined that the trial judge did not err in deciding not to continue past the first step of the Batson-Soares inquiry. In granting Defendant's petition for writ of habeas corpus, the First Circuit concluded that the trial judge unreasonably applied Federal law. Defendant then filed a motion for a new trial or, in the alternative, for a reduced sentence. The motion judge reduced the verdict under Mass. R. Crim. P. 25(b)(2) and resentenced Defendant. The Supreme Judicial Court vacated the order and remanded for retrial, holding (1) the judge improperly reduced the verdict, and the principles of double jeopardy did not preclude retrying Defendant; and (2) adopting the Federal formulation of the Batson-Soares test will better identify improper peremptory challenges. View "Commonwealth v. Sanchez" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree, armed assault with intent to murder, and animal cruelty, and declined to grant extraordinary relief under Mass. Gen. Laws ch. 278, 33E, holding that no prejudicial error occurred.Specifically, the Supreme Judicial Court held (1) no error occurred during jury selection with respect to the voir dire of prospective jurors; (2) the judge did not abuse her discretion in finding that the neutral reason provided by the prosecutor for exercising a peremptory challenge was genuine and adequate; (3) the judge did not abuse her discretion in admitting prior bad act evidence, testimony that Defendant had access to firearms, and testimony regarding the results of a criminalist's Internet search; (4) evidence of charred paper fragments found in the basement of the dwelling where Defendant lived was not relevant, but the error was not prejudicial; and (5) there was no error in the prosecutor's statements during closing argument. View "Commonwealth v. Mason" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of extreme atrocity or cruelty, holding that there was no error that resulted in a substantial likelihood of a miscarriage of justice.Specifically, the Supreme Court held (1) Defendant's statements that he made to police were properly admitted into evidence; (2) the trial judge did not err in finding that text messages sent after the murder were admissible; (3) the trial judge did not err in admitting a redacted version of the videotaped custodial interrogation of Defendant; (4) the trial judge did not err in declining to instruct the jury on involuntary manslaughter; (5) the trial judge did not err in denying Defendant's postconviction motion for a new trial; and (6) there was no reason to order a new trial or reduce the degree of guilt under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Lopez" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the decision of the Land Court judge ruling that the statutory scheme set forth in Mass. Gen. Laws ch. 60, 52 did not permit assignees of tax title accounts to include their own subsequent tax payments in the amount required for redemption, holding that the judge did not err.In 2011, City took tax title to Owners' property. Owners did not pay their real estate taxes in 2012 through 2015. In 2016, City assigned Appellant its tax title to the property. Appellant initiated proceedings to foreclose Owners' right to redeem the property. Owners exercised their right of redemption. In 2018, Appellant asked the Land Court to find that the redemption amount include the taxes owed to City at the time Appellant was assigned the tax title account, the taxes that Appellant had paid on the property from 2016 through 2018, and statutory interest on the unpaid real estate taxes and the taxes paid by Appellant. The judge concluded that tax payments made by section 52 assignees subsequent to the assignment of the tax title account could not be included in the redemption amount. The Supreme Judicial Court affirmed, holding that section 52 assignees of tax title accounts may not include their own subsequent tax payments, and interest thereon, in their redemption demands. View "Tallage Lincoln, LLC v. Williams" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree, holding that any claimed instructional errors did not give rise to a substantial likelihood of a miscarriage of justice and that Defendant did not receive ineffective assistance of counsel.On appeal, Defendant argued that the trial court erred by failing to instruct the jury concerning a lack of criminal responsibility and mental impairment and erred by failing properly to instruct the jury that they could consider evidence of intoxication when determining whether a murder was committed with extreme atrocity or cruelty. Defendant further argued that trial court's failure to remedy the instructional errors deprived him of the effective assistance of counsel. The Supreme Judicial Court affirmed, holding (1) there was no error in the jury instructions and, accordingly no substantial likelihood of a miscarriage of justice in counsel's handling of the instructions; and (2) there was no reason to reduce the verdict to one of murder in the second degree. View "Commonwealth v. Santiago" on Justia Law

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The Supreme Judicial Court reversed the order of the superior court granting summary judgment in favor of Dorchester Mutual with respect to its duty to indemnify the parents of Timothy Krusell, holding that the allowance of summary judgment in favor of Dorchester Mutual was error.Timothy pushed Robert Haufler on a sidewalk, causing him to fall and sustain injuries. Haufler brought a personal injury action against the Krusells. Dorchester Mutual sought a declaratory judgment that it had no duty to indemnify the Krusells under a homeowners' insurance policy for Haufler's personal injury claims because Timothy's conduct was a form of "physical abuse" for which coverage was unavailable. A superior court judge concluded that coverage was precluded. The Supreme Judicial Court reversed, holding (1) the term "physical abuse," as used in the policy, was ambiguous, but a reasonable insured would interpret the term as not precluding coverage for Haufler's claim; and (2) there was no error in the allowance of summary judgment on so much of the Krusell's cross claim as asserted violations of Mass. Gen. Laws ch. 93A and Mass. Gen. Laws ch. 176D. View "Dorchester Mutual Insurance Co. v. Krusell" on Justia Law

Posted in: Insurance Law
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The Supreme Judicial Court denied Defendant's motion for attorney's fees and costs made by an attorney who claimed to have been privately retained by Defendant for the purpose of opposing the Commonwealth's application for leave to appeal, holding that no attorney's fees are required under Mass. R. Crim. P. 15(d) in this situation.Defendant, who was indigent, was convicted of murder in the second degree and two firearm offenses. Before trial, Defendant filed motions to suppress a variety of evidence. After the trial judge ruled on the motions, both sides sought leave to appeal from the rulings that were adverse to them. The Supreme Court affirmed in part and reversed in part. At issue was the attorney's fees request by the attorney claiming to be privately retained by Defendant. The Supreme Judicial Court denied the request, holding that Rule 15(d) was not meant for attorneys who represent defendants whom they know to be indigent and from whom they never expect to receive payment. View "Commonwealth v. Vasquez" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on a theory of extreme atrocity or cruelty, holding that the errors that occurred during the trial did not require a new trial.On appeal, Defendant argued that she was prejudiced from the Commonwealth's use of prior bad act evidence. The Supreme Judicial Court affirmed, holding (1) some of the challenged evidence should not have been admitted, but there was no abuse of discretion int he judge's conclusion that the probative value of the evidence was not outweighed by its prejudicial effect; (2) the prosecutor's reliance on the prior bad act evidence in closing arguments was improper, but the improprieties did not so infuse the trial with unfairness as to deny due process of law; and (3) a reduction in the verdict pursuant to Mass. Gen. Laws ch. 278, 33E would not serve the interests of justice. View "Commonwealth v. Peno" on Justia Law