Justia Massachusetts Supreme Court Opinion Summaries

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The Supreme Judicial Court vacated certain portions of a trial judge's nondisparagement orders issued to the parties in this case in an attempt to protect the psychological well-being of the parties' minor child, holding that the nondisparagement orders here operated as an impermissible prior restraint on speech. After Mother filed for divorce from Father, Mother filed a motion for temporary orders, including a request that the judge prohibit Father from posting disparaging remarks about her and the ongoing litigation on social media. The judge issued temporary orders that included nondisparagement provisions against both parties. Thereafter, Mother filed a complaint for civil contempt alleging that Father violated the first order. A different judge declined to find contempt on the ground that the first order, as issued, constituted an unlawful prior restraint of speech in violation of Father's constitutional rights. The Supreme judicial Court agreed, holding that the nondisparagement orders were unconstitutional. View "Shak v. Shak" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty and declined to exercise its power pursuant to Mass. Gen. Laws ch. 278, 33E to reduce the conviction to manslaughter, holding that there was no reversible error in the proceedings below. Specifically, the Supreme Judicial Court held (1) the trial judge did not err by denying Defendant's requests for a jury instruction pursuant to Commonwealth v. Croft, 345 Mass. 143 (1962); (2) the trial judge did not err by denying Defendant's motions for a required finding of not guilty under Croft because a rational jury could have found that Defendant was guilty of murder in the first degree on both the theories of premeditation and extreme atrocity or cruelty; and (3) there was no basis for reducing Defendant's sentence or ordering a new trial. View "Commonwealth v. Tavares" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree and the denial of his motion for a new trial and declined to exercise its authority under Mass. Gen. Laws ch. 278E to reduce Defendant's conviction to murder in the second degree, holding that Defendant was not entitled to relief on any of his allegations of error. Defendant was convicted of murder in the first degree on the theory of felony-murder. Defendant filed a motion for a new trial, which was denied. The Supreme Judicial Court affirmed, holding (1) Defendant's motion for a new trial was correctly denied because Defendant was not prejudiced by counsel's ineffective assistance; (2) this Court declines to extend the reach of the Court's holding in Commonwealth v. Brown, 477 Mass. 805 (2017), to Defendant's case; and (3) trial judge erred when he declined Defendant's request that the jury be instructed on the elements of voluntary and involuntary manslaughter, but the error was not prejudicial in the context of the judge's other instructions. View "Commonwealth v. Martin" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions and the decision of the Appeals Court denying Defendant's motion to vacate the entry of his appeal from his convictions in that court and to have the case entered directly in the Supreme Judicial Court, holding that a direct appeal from the third conviction of a habitual offender pursuant to Mass. Gen. Laws ch. 279, 25(b) may be entered in the Appeals Court. Defendant was indicted for serious felonies arising from a brutal attack and rape. In addition to charging the specific felony, each indictment also alleged that the sentence for that felony should be enhanced pursuant to the habitual criminal provision Mass. Gen. Laws ch. 279, 25(a) or the habitual offender provision of section 25(b), or both. After he was convicted, Defendant moved to have the case entered directly in the Supreme Judicial Court. The Appeals Court denied the motion. The Supreme Judicial Court affirmed Defendant's convictions, holding (1) this direct appeal was entitled to the unique review prescribed by Mass Gen. Laws ch. 278, 33E, and the Appeals Court may conduct such section 33E review; (2) Defendant was not impermissibly allowed to waive his right to a jury trial on the sentencing enhancement provisions of the indictments; and (3) Defendant was not entitled to reversal of his convictions on any other ground. View "Commonwealth v. Billingslea" on Justia Law

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The Supreme Judicial Court dismissed Plaintiff's complaint seeking relief in the nature of mandamus, holding that mandamus relief did not lie with respect to Plaintiff's challenges to discretionary decisions of the superior court. Plaintiff's requests for relief related to postconviction motions and other requests Plaintiff made in a criminal proceeding in the superior court to withdraw his guilty plea. Plaintiff requested several clarifications and that the Court provide a "speedy remedy" for other alleged instances of inaction or misconduct by the superior court in failing to provide relief. The Supreme Judicial Court denied relief, holding that Plaintiff failed to make a showing that alternative avenues of relief were inadequate. View "In re Burnham" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition for extraordinary relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused her discretion in denying relief. Petitioner primarily sought relief from a superior court judgment revoking his probation and imposing a suspended sentence. In his petition, Petitioner argued that the superior court's reliance on his mental health issues and treatment in refusing to re-probate him violated the Federal Americans with Disabilities Act. The single justice denied relief. The Supreme Judicial Court affirmed, holding that Petitioner's claims were appropriately raised in a direct appeal from the revocation of his probation. View "Burnham v. Commonwealth (No. 1)" on Justia Law

Posted in: Criminal Law
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In this case regarding the mitigation of the spread of COVID-19 in the Commonwealth's prison decision the Supreme Judicial Court affirmed its prior decision, issued on April 3, 2020, as to the extent of the Court's constitutional authority to stay final sentences absent an ongoing challenge to the underlying conviction or a violation of constitutional rights, holding that the global stays of sentences sought by Petitioners would co-opt executive functions in ways that are not permitted by article 30 of the Massachusetts Declaration of Rights. Petitioners asked the Supreme Judicial Court to reconsider its determination that neither the Court's inherent judicial authority nor its superintendence authority permitted a judge to stay a final sentence that is being served, absent a pending appeal or a motion for a new trial, without violating separation of powers principles under article 30. Petitioners further challenged the court's order with respect to reporting requirements. The Supreme Judicial Court affirmed its prior decision but concluded that some of the requested relief as to additional reporting requirements should be allowed, and accordingly issued a revised Appendix B. View "Committee for Public Counsel Services v. Chief Justice of the Trial Court (No. 2)" on Justia Law

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The Supreme Judicial Court affirmed the order of the superior court granting Plaintiff's motion for a preliminary injunction seeking immediate reinstatement to school after she was suspended for 152 school days for possessing a small amount of marijuana and two makeshift pipes in her locker at a public high school, holding that the motion judge did not err in concluding that Plaintiff was likely to succeed on the merits of her claim. When Plaintiff appealed from her suspension to the superintendent, the district's school safety director acting as the superintendent's designee shorted the suspension to 112 school days. Plaintiff filed a complaint alleging that, by delegating the appeal to the school safety director, Defendants failed to comply with the procedure for appealing from the expulsion set forth in Mass. Gen. Laws ch. 71, 37H(d). Plaintiff also filed an emergency motion for a preliminary injunction. The motion judge granted the preliminary injunction and reinstated Plaintiff to her high school. The Supreme Judicial Court affirmed, holding that because the principal initially imposed a suspension of 152 school days, Plaintiff was entitled under section 37H to appeal from her exclusion directly to the superintendent, not a designee of the superintendent. View "Doe v. Worcester Public Schools" on Justia Law

Posted in: Education Law
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The Supreme Judicial Court affirmed the order of the superior court finding that Defendant committed a breach of contract and the implied covenant of good faith and fair dealing and awarding $10.2 million in damages, holding that the superior court did not abuse its discretion. The jury awarded Plaintiff in excess of $22 million in damages after Defendant withdrew its support for Plaintiff's research laboratory. The judge conditionally ordered a new trial unless Plaintiff agreed to remit all but $10.2 million of the awarded damages, which represented in part $10 million that Plaintiff testified was necessary to reestablish her laboratory. The Supreme Judicial Court affirmed, holding (1) the trial evidence supported the finding that Defendant committed a breach of both the express terms of the contract and the implied covenant of good faith and fair dealing; (2) the cost of reestablishing the laboratory was a permissible element of the damages; and (3) the judge did not abuse her discretion in adding a remittitur of all but $10.2 million of the award of damages. The judges were equally divided as to whether the $10 million should go to Plaintiff outright or subject to a restriction, and therefore, the award of damages stood without any restriction. View "Hlatky v. Steward Health Care System, LLC" on Justia Law

Posted in: Contracts
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The Supreme Judicial Court affirmed the decision of the superior court granting summary judgment in favor of Susan Boss on her complaint seeking a declaration that the Town of Leveret was obligated to pay fifty percent of the full premium cost for health insurance for retired town employees and their dependent spouses, holding that by adopting Mass. Gen. Laws ch. 32B, 9A, the Town was required to cover fifty percent of the premiums for both retirees and the retirees' dependents. Boss was a retired Town employee. Since her retirement, the Town had paid fifty percent of her premium contribution based only on the premium cost for individual coverage. Consequently, Boss had been responsible for covering the balance of the plan premium in order to continue coverage for her spouse. Since become Medicare eligible, Boss continued to pay the full premium for her husband's individual plan. After Boss brought this action the superior court granted summary judgment in her favor. The Supreme Judicial Court affirmed, holding (1) the Town's adoption of section 9A obligated it to contribute toward the premiums associated with retirees' dependents; and (2) section 9A was successfully adopted at the Town meeting on April 24, 2004. View "Boss v. Town of Leverett" on Justia Law