Justia Massachusetts Supreme Court Opinion Summaries

The defendant was charged with assault and battery on a family or household member and was detained pretrial. While awaiting trial, he made two recorded phone calls to his fiancée, the alleged victim, advising her not to cooperate with authorities. He suggested that if she did not testify, the case against him would weaken. The fiancée expressed concerns about losing her housing and custody of her children due to police and Department of Children and Families (DCF) involvement. The defendant reassured her that things would improve if she followed his advice.The case was initially heard in the Lynn Division of the District Court Department, where the defendant was found guilty of witness intimidation under G. L. c. 268, § 13B. The judge denied the defendant's motion for a required finding of not guilty. The defendant appealed, and the Appeals Court affirmed the conviction. The Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed whether the defendant's statements constituted an offer or promise of anything of value to dissuade his fiancée from testifying. The court found that the Commonwealth failed to prove beyond a reasonable doubt that the defendant's vague assurances about their relationship and the potential end of the DCF investigation constituted a bribe. The court noted that the defendant did not have the power to influence the DCF investigation and that his statements did not amount to a quid pro quo arrangement. Consequently, the court reversed the conviction, set aside the finding, and ordered that judgment be entered for the defendant. View "Commonwealth v. Bellard" on Justia Law

A juvenile was indicted as a youthful offender for unarmed carjacking, unarmed assault with intent to rob, and assault and battery on an elder. The charges stemmed from an incident where the juvenile, after escaping from a secure facility, attacked an elderly man and stole his car. The juvenile pleaded guilty and was sentenced to two years in a house of correction followed by five years of probation.The Juvenile Court initially sentenced the juvenile to a house of correction, but after multiple probation violations, including missing appointments and being involved in new offenses, the court sentenced him to State prison. The juvenile appealed the sentence, arguing it was unlawful and that the judge did not adequately consider his well-being and the impact of recent literature on juvenile brain development.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the juvenile's sentence was lawful under G. L. c. 119, § 58, which allows for adult sentences, including State prison, for youthful offenders. The court determined that the Juvenile Court judge had appropriately considered the juvenile's criminal history, noncompliance with probation, and the need for public safety. The court also concluded that the judge did not need to make specific written findings on the impact of juvenile brain development literature.Additionally, the Supreme Judicial Court held that the Appellate Division of the Superior Court is authorized to review sentences to State prison imposed by the Juvenile Court on youthful offenders. This ensures that youthful offenders have the same procedural safeguards as adult criminal defendants. The court affirmed the juvenile's sentence and allowed for the appeal to the Appellate Division. View "Commonwealth v. Y." on Justia Law

The juvenile in this case was on probation after being adjudicated as a youthful offender for breaking and entering a vehicle with intent to commit a felony. While on probation, he began experiencing severe mental health issues, including hallucinations and delusions, which led him to obtain a firearm illegally. His mother called the police, and he was found in possession of a loaded firearm without a license. This led to new criminal charges and a notice of probation violation for not obeying state laws.The Juvenile Court judge found that the juvenile violated his probation by possessing the firearm and revoked his probation, sentencing him to incarceration. The judge ruled that the defense of lack of criminal responsibility was not available in probation violation hearings but considered the juvenile's mental illness in determining the disposition. The juvenile appealed, arguing that due process requires allowing the defense of lack of criminal responsibility in probation violation hearings.The Supreme Judicial Court of Massachusetts reviewed the case and held that the affirmative defense of lack of criminal responsibility is not required in probation violation hearings. The court reasoned that the primary inquiry in such hearings is whether the probationer violated a condition of probation, not whether the probationer is criminally responsible. However, the court acknowledged that evidence of mental illness is relevant to determining whether a violation was willful and in deciding the appropriate disposition. The court affirmed the lower court's decision, finding no error in the judge's ruling or abuse of discretion in revoking the juvenile's probation and imposing a sentence of incarceration. View "Commonwealth v. Z." on Justia Law

The plaintiff, Jane Doe, alleged that she was sexually assaulted by court officer Jose Martinez while in custody at the Lawrence District Court in 2009 and 2014. Doe claimed that the Massachusetts Trial Court was negligent in failing to prevent these assaults. She reported the 2009 assaults to the New Hampshire Department of Corrections, but they did not inform the Trial Court. In 2014, after further assaults, she again reported to New Hampshire authorities, who then notified the Massachusetts State Police, leading to Martinez's arrest in 2015. Additionally, in 2013, another detainee accused Martinez of groping her, but an investigation by the Lawrence police and the Trial Court did not substantiate the claim.The Superior Court granted summary judgment in favor of the Trial Court, concluding that the Massachusetts Tort Claims Act (MTCA) immunized the Trial Court from suit under the discretionary function exception. The judge also noted that the MTCA's public duty rule provided an alternative basis for summary judgment.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The court held that the Trial Court's decisions regarding detainee safety policies and procedures involved discretionary functions protected by the MTCA. The court found that the Trial Court had discretion in implementing policies to ensure detainee safety and that these decisions were integral to policy-making and planning. The court also noted that the Trial Court's actions were not prescribed by any statute or regulation, including the Prison Rape Elimination Act (PREA), which did not mandate immediate compliance with its standards. Therefore, the Trial Court was immune from liability under the MTCA's discretionary function exception. View "Doe v. Massachusetts Trial Court" on Justia Law

The defendant was convicted of murder in the first degree, armed assault with intent to murder, and assault and battery by means of a dangerous weapon. The charges stemmed from his role as the getaway driver after a shooting in Charlestown, Boston, where two men in hooded sweatshirts shot Ryan Morrissey and Jamie Lawton outside a convenience store, killing Morrissey and seriously injuring Lawton. Witnesses saw the assailants flee on foot and enter a car driven by the defendant. The car was later identified as belonging to the defendant's mother.In the Superior Court, the defendant was tried jointly with two alleged assailants, Danilo Soto and Alexander Soto, who were acquitted by the jury. The defendant was found guilty on all charges. He appealed, arguing insufficient evidence to prove he was the driver and that he shared the assailants' lethal intent. He also challenged the trial judge's decisions on jury selection and the admissibility of expert testimony.The Supreme Judicial Court of Massachusetts reviewed the case. The court found sufficient evidence to establish that the defendant was the getaway driver. However, it concluded that there was insufficient evidence to prove that the defendant knew of or shared the assailants' lethal intent. The court emphasized that the evidence did not show the defendant knew the assailants were armed or intended to kill the victims. Consequently, the court reversed the defendant's convictions of murder in the first degree, armed assault with intent to murder, and assault and battery by means of a dangerous weapon, and remanded the case for entry of a required finding of not guilty. View "Commonwealth v. Baez" on Justia Law

A severe thunderstorm caused significant damage to Norwood Hospital, owned by Medical Properties Trust, Inc. (MPT) and leased to Steward Health Care System LLC (Steward). The storm led to extensive flooding in the hospital's basements and rainwater accumulation on the rooftop courtyard and parapet roofs, which then seeped into the building, causing further damage. MPT and Steward sought coverage from their insurers, Zurich American Insurance Company (Zurich) and American Guarantee and Liability Insurance Company (AGLIC), respectively. Both policies had high overall coverage limits but lower sublimits for flood damage. The insurers argued that all the damage was due to "Flood" as defined in the policies, which included "surface waters," and thus subject to the lower sublimits.The United States District Court for the District of Massachusetts granted partial summary judgment to the insurers, interpreting "surface waters" to include rainwater accumulated on the roofs. The court allowed an interlocutory appeal, recognizing the substantial ground for difference of opinion on this legal issue. The United States Court of Appeals for the First Circuit then certified the question to the Supreme Judicial Court of Massachusetts, asking whether rainwater accumulating on a building's rooftop courtyard or parapet roof constitutes "surface waters" under Massachusetts law.The Supreme Judicial Court of Massachusetts concluded that the term "surface waters" is ambiguous in this context. The court noted the lack of a clear definition in the policies and the divided case law on the issue. Given this ambiguity, the court ruled in favor of the insureds, determining that rainwater accumulating on the rooftop courtyard and parapet roofs does not unambiguously constitute "surface waters" under the policies. Therefore, the damage from such water infiltration is not subject to the flood sublimits. View "Zurich American Insurance Company v. Medical Properties Trust, Inc." on Justia Law

The defendant was convicted of reckless endangerment of a child and witness intimidation after attacking her twelve-year-old son. The incident began with an argument about the son's dental braces, leading the defendant to contemplate suicide. The next morning, she attempted to kill her son by stabbing him in the neck and trying to drown him. The son managed to escape and tried to call 911, but the defendant took his phone and told the dispatcher everything was fine. The son eventually called the police, who found him injured and the defendant attempting to harm herself.The defendant was indicted on multiple charges, including assault and battery by means of a dangerous weapon and attempted murder. After a bench trial, the Superior Court judge found her not guilty by reason of mental illness for the assault and attempted murder charges but guilty of reckless endangerment and witness intimidation. She was sentenced to five years of probation with conditions, including no unsupervised contact with her children and GPS monitoring for two years. The defendant appealed, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court upheld the convictions, finding sufficient evidence that the defendant was criminally responsible for her actions after the attack. The court determined that the defendant understood the criminality of preventing her son from calling 911 and could conform her conduct to the law. The court also found the indictment for reckless endangerment was not impermissibly ambiguous and that the GPS monitoring condition of probation was reasonable. The court affirmed the convictions and the probation condition. View "Commonwealth v. Rezac" on Justia Law

The case involves the defendant, Maryann Russo, who was charged with animal cruelty under G. L. c. 272, § 77, for her treatment of her terminally ill fourteen-year-old cocker spaniel, Tipper. Russo brought Tipper to a veterinarian who recommended euthanasia due to Tipper's severe health issues, including a large necrotic mass, bed sores, and open wounds. Russo declined euthanasia, falsely stating she would take Tipper to another veterinarian, and instead took him home. The Animal Rescue League (ARL) later removed Tipper from Russo's care after the veterinarian reported her suspicions. Tipper was found in poor condition and was subsequently euthanized.In the Quincy Division of the District Court, a criminal complaint was issued against Russo in February 2021. Russo filed a motion to dismiss the complaint, arguing it lacked probable cause. The District Court judge granted the motion, concluding that the statute did not impose an affirmative obligation to euthanize an animal. The Commonwealth appealed, and the Appeals Court affirmed the dismissal, reasoning that the statute did not criminalize the failure to euthanize an animal. The Supreme Judicial Court granted further appellate review.The Supreme Judicial Court affirmed the dismissal, holding that the Commonwealth failed to establish probable cause that Russo acted with the requisite criminal intent. The court concluded that the statute required proof that Russo knowingly and willfully authorized or permitted Tipper to be subjected to unnecessary suffering. The court found that Russo's actions, including seeking medical care and attempting to make Tipper comfortable, did not indicate an intent to cause unnecessary suffering. The court emphasized that speculation alone was insufficient to establish probable cause. View "Commonwealth v. Russo" on Justia Law

In 2016, the Federal National Mortgage Association (Fannie Mae) acquired the high bid at a foreclosure sale of Anthony Michael Branch's property. Fannie Mae then initiated a summary process action in the Housing Court to gain possession. The court ruled in favor of Fannie Mae, and Branch appealed. During the appeal, Fannie Mae sold the property to Roberto Pina Cardoso. Cardoso intervened in the case and was awarded use and occupancy payments from Branch. The Appeals Court later vacated the Housing Court's judgment for possession, declaring it moot since Fannie Mae no longer had a possessory interest, and required Cardoso to establish his right to possession in a new case.The Housing Court initially granted summary judgment in favor of Fannie Mae for possession and dismissed Branch's counterclaims. Branch appealed, and during the appeal, Cardoso was allowed to intervene and was joined as a party with Fannie Mae. The Appeals Court vacated the judgment for possession as moot but affirmed the dismissal of Branch's counterclaims.The Supreme Judicial Court of Massachusetts reviewed the case and disagreed with the Appeals Court's mootness determination. The court held that Cardoso, having acquired Fannie Mae's interest, maintained a live stake in the adjudication of the judgment for possession. The court affirmed the Housing Court's order allowing Cardoso to intervene and be joined as a party. It also affirmed the summary judgment in favor of Fannie Mae for possession and the dismissal of Branch's counterclaims. The court concluded that the foreclosure was valid and that Pentagon Federal Credit Union, as the authorized agent of the note holder, had the authority to foreclose. View "Fannie Mae v. Branch" on Justia Law

The defendant was convicted of first-degree murder for the stabbing death of Jordan Baskin. After his conviction, the defendant filed a motion for a new trial, claiming his trial counsel provided ineffective assistance during a police interview where incriminating evidence was obtained. The defendant argued that his trial counsel failed to provide effective representation and had a conflict of interest because filing a motion to suppress the evidence would have been against her own interests.The Superior Court judge allowed the motion for a new trial, finding that the trial counsel had an actual conflict of interest and that the defendant did not waive this conflict knowingly and intelligently. The judge concluded that the conflict alone warranted a new trial without needing to show additional prejudice.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The court found that the trial counsel's personal interests materially interfered with her independent professional judgment, creating an actual conflict of interest. This conflict arose because the trial counsel's performance during the police interview was in question, and she could not provide detached advice or pursue a motion to suppress the evidence obtained during the interview zealously. The court also determined that the defendant did not validly waive this conflict, as the colloquies before trial did not address the specific conflict related to the adequacy of counsel's performance at the police interview. Therefore, the court affirmed the order for a new trial. View "Commonwealth v. Brown" on Justia Law