Justia Massachusetts Supreme Court Opinion Summaries

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The Supreme Judicial Court held that the $1.25 fee cap set forth in Mass. Gen. Laws ch. 262, 41 applies only to a particular notarial act known as "noting," and that the meaning of that section has not been expanded to include all notarial acts.The question at issue in this case arose in connection with a lawsuit in which Plaintiff alleged that Defendants - The UPS Store, Inc., and J&V Logistics LLC, the franchise owner - overcharged him for notary services. Plaintiff alleged violations of Mass. Gen. Laws ch. 262, 41 and Mass. Gen. Laws ch. 93A. Defendants removed the case to the federal district court. Thereafter, Defendants moved to certify to the Supreme Judicial Court the question of whether section 41 applies to all notarial acts, as argued by Plaintiff. The district court certified the question. The Supreme Judicial Court held that Mass. Gen. Laws ch. 262, 41 and 43 to not proscribe fees for acts unrelated to the protest of a negotiable instrumented that, aside from section 41, there are currently no statutes or executive orders that cap fees for any other notarial act. View "Richardson v. UPS Store, Inc." on Justia Law

Posted in: Consumer Law
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The Supreme Judicial Court affirmed the judgment of the district court judge in this civil commitment matter, holding that sufficient admissible evidence was presented to warrant an order to civilly commit J.P. for a period not to exceed six months pursuant to Mass. Gen. Laws ch. 123, 7, 8.Southcoast Behavioral Health filed a timely petition for J.P.'s involuntary commitment, alleging that, as a result of mental illness, J.P. presented a risk of harm to others and a substantial risk of harm to himself and that civil commitment was the least restrictive alternative in the circumstances. After a hearing, the judge ordered J.P. civilly committed for a period not to exceed six months. The Supreme Judicial Court affirmed, holding (1) the judge improperly considered certain evidence because it was inadmissible hearsay, but J.P. suffered no prejudice from the admission of this evidence; and (2) there was sufficient evidence presented to support the civil commitment order. View "In re J.P." on Justia Law

Posted in: Health Law
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The Supreme Judicial Court affirmed the decision of the reviewing board of the Department of Industrial Accidents (department) concluding that marijuana's status as a federally illicit substance preempted any state level authority to order a workers' compensation insurer to pay for Daniel Wright's medical marijuana expenses, holding that the workers' compensation insurer in this case could not be required to pay for medical marijuana expenses.Wright sought compensation for $24,267 of medical marijuana expenses to treat chronic pain stemming from two work-related injuries. An administrative judge denied his claim, and the reviewing board affirmed. The Supreme Judicial Court affirmed, holding that the reimbursement limitation provision contained within the Commonwealth's medical marijuana act, St. 2012, c. 369, 7, prevents a health insurance provider or government agency from being ordered to reimburse a claimant for medical marijuana expenses. View "Daniel Wright's Case" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the single justice of the Court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner was indicted on several counts of rape and one count of strangulation or suffocation. Petitioner was committed for observation to Bridgewater State Hospital for a determination whether he was competent to stand trial. Petitioner was found incompetent to stand trial and committed to the hospital pursuant to Mass. Gen. Laws ch. 123, 16. Petitioner, who remains in the hospital, filed a Mass. Gen. Laws ch. 211, 3 petition claiming, among other things, that his constitutional rights had been violated. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that Petitioner had an adequate alternative remedy and that his claims did not present a situation warranting extraordinary superintendence relief pursuant to Mass. Gen. Laws ch. 211, 3. View "Ardaneh v. Commonwealth" on Justia Law

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The Supreme Judicial Court vacated the order of the superior court denying Appellant's motion for refund of parole supervision fees she paid while on parole, holding that Appellant was entitled to return of the parole fees she paid.Appellant's convictions were vacated and the charges against her dismissed with prejudice due to the misconduct of Annie Dookhan, a chemist at the William A. Hinton State Laboratory Institute. Appellant subsequently filed a motion in her criminal case seeking a refund of the parole supervision fees that she had paid as a result of her invalidated convictions and a waiver of the remaining balance she owed. The superior court denied the motion, concluding that a motion filed in the criminal case was not the correct way to seek a refund of parole fees. The Supreme Judicial Court vacated the judgment, holding (1) Appellant was entitled to a return of her previously paid parole fees; and (2) Appellant correctly filed her motion for a refund in the same criminal case in which her convictions had been invalidated. View "Commonwealth v. Nieves" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Defendant's petition under Mass. Gen. Laws ch. 211, 3 for relief from home confinement as a condition of his bail, holding that the single justice properly denied relief.Defendant was charged with open and gross lewdness, subsequent offense. At Defendant's arraignment, a district court judge set bail and, as a condition of release, ordered that Defendant be subject to GPS monitoring and confined to the interior of his home. Defendant was released subject to these conditions. Defendant later filed his Mass. Gen. Laws ch. 211, 3 petition challenging the order of home confinement. The single justice denied relief. The Supreme Judicial Court affirmed, holding the bail judge was within his discretion to order Defendant to remain inside the house. View "Falcone v. Commonwealth" 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 unlawful possession of a firearm, holding that no error occurred during the proceedings below.Specifically, the Supreme Judicial Court held (1) one of the Commonwealth's key witnesses did not provide improper lay testimony on the ultimate issue of Defendant's guilt; (2) Defendant's argument that a substantial likelihood of a miscarriage of justice occurred because the judge did not provide a self-defense instruction sua sponte was without merit; (3) trial counsel did not provide ineffective assistance for strategically deciding against requesting a self-defense instruction; and (4) there was no basis to set aside the verdict of murder in the first degree or to order a new trial pursuant to the Court's extraordinary power under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Waller" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree by deliberate premeditation and assault with intent to murder, holding that no error occurred in the proceedings below.Specifically, the Supreme Judicial Court held (1) the motion judge did not err in denying Defendant's motion to suppress because (a) although Defendant unambiguously invoked his right to counsel, he voluntarily reinitiated contact with detectives, and (b) Defendant's waiver of his Miranda rights was intelligent, knowing, and voluntary; (2) factually inconsistent verdicts were no grounds to set aside Defendant's convictions of murder in the first degree and assault with the intent to murder because ample evidence supported both convictions; and (3) the verdict of murder in the first degree was consonant with justice, and there was no basis to set aside the verdict or order a new trial pursuant to the Court's extraordinary power under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Miller" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of deliberate premeditation, holding that there was no prejudicial error in the proceedings below.After Defendant was convicted of murder, the Supreme Judicial Court reversed the conviction due to an error in the jury instructions. Following a retrial, Defendant was again convicted of murder. Defendant filed a motion for a new trial, which the trial court denied. The Supreme Judicial Court affirmed, holding (1) the trial judge's decision to allow a witness to avoid testifying at the second trial by invoking the privilege against self-incrimination and in admitting the witness's voir dire testimony, in lieu of live testimony at the second trial, did not create a substantial likelihood of a miscarriage of justice; (2) the trial court did not err in denying Defendant's motion for a new trial on the ground that he suffered from a mental disease or defect at the time of the shooting; (3) this Court again declines to extend its holding in Diatchenko v. District Attorney for the Suffolk District, 466 Mass. 655 (2013), to individuals over the age of eighteen; and (4) Defendant's arguments made pursuant to Commonwealth v. Moffett, 383 Mass. 201, 208-209 (1981) were unavailing. View "Commonwealth v. Johnson" on Justia Law

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The Supreme Judicial Court answered a question certified to it by the United States Court of Appeals for the First Circuit, holding that the assets of a self-settled discretionary spendthrift irrevocable trust governed by Massachusetts law are not protected from a reach and apply action by the deceased settlor's creditors.Specifically, the Supreme Judicial Court concluded that, based on the circumstances presented in this case and consistent with the well-established public policy of the Commonwealth, when a settlor creates a self-settled spendthrift irrevocable trust that is governed by Massachusetts law and that allowed unlimited distributions to the settlor during his lifetime, and a judgment-creditor's cause of action accrues prior to the settlor's death, a judgment-creditor of the settlor's estate may reach and apply the trust's assets after the settlor's death. View "De Prins v. Michaeles" on Justia Law

Posted in: Trusts & Estates