Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the first degree. The Supreme Court affirmed the conviction and the denial of Defendant's motion for a new trial. Defendant later filed a second motion for a new trial, alleging that his counsel was ineffective for failing to raise certain alleged errors at trial and on direct appeal. The superior court denied the motion. The Supreme Court affirmed the order denying the motion for a new trial, holding (1) trial counsel was not constitutionally ineffective in failing to object to two courtroom closures; (2) the trial judge improperly limited the scope of Defendant's cross-examination of a witness for the prosecution, but the error was harmless; (3) Defendant's appellate counsel was not ineffective for failing to cite federal law to support Defendant's claims of error on direct appeal; (4) the trial judge did not err in declining to give a Bowden instruction; and (5) the trial judge properly instructed the jury on consciousness of guilt. View "Commonwealth v. Hardy" on Justia Law

Defendant purchased an "own occupation" disability insurance policy from an affiliate of Plaintiff, Metropolitan Life Insurance Company (MetLife). After Defendant was diagnosed with cancer, Defendant's employment was terminated. Defendant filed a clam for disability benefits and began receiving disability payments. Defendant later began working at a lower stress job. MetLife concluded that Defendant was no longer eligible to receive disability benefits. Metlife reached this conclusion by interpreting a clause in Defendant's policy requiring Defendant to receive care by a physician that "is appropriate for the condition causing the disability" to mean that Defendant was required to pursue treatment aimed at returning him to his prior occupation. MetLife filed an action seeking a judgment declaring it had no continuing obligation to pay benefits to Defendant and reimbursement of benefits it had paid. The superior court declared MetLife was not required to continue paying Defendant benefits but that MetLife was not entitled to restitution of any benefits paid. The Supreme Court affirmed, holding (1) Defendant was not entitled to benefits under the policy since he was not receiving care designed to enable him to return to him prior occupation; and (2) MetLife was not entitled to reimbursement for benefits paid to Defendant. View "Metro. Life Ins. Co. v. Cotter" on Justia Law

This action arose from the Department of Environmental Protection's (Department) issuance of a waterways license under Mass. Gen. Laws ch. 91 (chapter 91 license) to the Boston Redevelopment Authority (BRA) to redevelop a section of land owned by the BRA on the seaward end of Long Wharf (project site). Plaintiffs, ten residents of Boston's North End neighborhood, appealed the issuance of the chapter 91 license, claiming the Department acted unconstitutionally and beyond its statutory authority when it issued the license without obtaining two-thirds vote of the Legislature as required by article 97 of the amendments to the Massachusetts Constitution. After the a Department's office of appeals affirmed the issuance of the license, the superior court ordered declaratory relief and issued a writ of mandamus ordering the Department to enforce article 97. The Supreme Court reversed, holding that article 97 did not apply to the project site, and therefore, a two-thirds vote of the Legislature was not required to approve the planned development. Remanded. View "Mahajan v. Dep't of Envtl. Prot." on Justia Law

After a jury trial, Defendant was convicted of carrying a firearm without a license based on a theory of constructive possession. Defendant appealed, contending, among other things, that the Commonwealth failed to present sufficient evidence to establish as a matter of law that Defendant had knowledge of the firearm's presence in his vehicle, the ability to exercise control over the weapon, and the intent to do so. The Supreme Court reversed Defendant's conviction and directed that a verdict of not guilty be entered, holding that although the evidence proffered by the Commonwealth was adequate to establish that Defendant knew the firearm was present in the motor vehicle he was operating and that he had the ability to exercise control over the weapon, the evidence was insufficient to prove Defendant had the requisite intention to control the firearm. View "Commonwealth v. Romero" on Justia Law

Defendant was indicted on drug-related charges that included trafficking in cocaine over twenty-eight grams. During the trial, certificates of chemical analysis establishing the weight and identity of the substance alleged to have been in Defendant's possession (drug certificates) were admitted into evidence. Defendant was convicted of the charges. After Defendant appealed, the U.S. Supreme Court issued its decision in Melendez-Diaz v. Massachusetts, which held that a drug analyst's certificate is testimonial and cannot be admitted at trial unless a defendant has the opportunity to cross-examine the analyst. Defendant then filed a motion for a new trial, arguing that the admission of the drug certificates violated his right to confrontation. The judge denied the motion, concluding that admission of the drug certificates was harmless beyond a reasonable doubt. The Supreme Court vacated Defendant's convictions and remanded the case for a new trial, holding that the erroneous admission of the drug certificates was not harmless beyond a reasonable doubt. View "Commonwealth v. Montoya" on Justia Law

Defendant was convicted of the deliberately premeditated murder of his wife. The Massachusetts Supreme Court affirmed, but the U.S. Supreme Court vacated the judgment and remanded the case in light of the recent U.S. Supreme Court decision in Williams v. Illinois, which addressed the admissibility under the Confrontation Clause of expert testimony about the results of DNA testing performed by non-testifying analysts. On remand, the Court reconsidered of the admissibility of testimony of an expert witness regarding DNA testing where the witness did not prepare the underlying data. The Supreme Court affirmed, holding (1) the Court's rules of evidence and the protections they afford are not inconsistent with Williams; (2) the witness's expert opinion that Defendant's DNA matched the DNA on items recovered from the crime scene was properly admitted; and (3) the witness's direct testimony to the details of the DNA test results of a nontestifying analyst was improperly admitted, but Defendant was not prejudiced by the erroneous admission. View "Commonwealth v. Greineder" on Justia Law

Construction Company contracted with Subcontractor for construction of elements of an HVAC system. As partial collateral for a revolving line of credit, Subcontractor assigned to Bank its right to receive payment under the contract with Construction Company. Construction Company instead made twelve payments to Subcontractor. Subcontractor subsequently ceased business operations, leaving an outstanding debt to Bank on its line of credit. Bank filed an action against Construction Company for breach of contract and violation of the UCC. A jury found (1) Construction Company liable on both counts for ten of the twelve checks that it had delivered to Subcontractor, and (2) Bank was estopped from recovering with respect to the final two checks. The judge entered judgment on the statutory claim in the amount of $3,015,000, the full face value of the ten checks. The Supreme Court affirmed in part and reversed in part, holding that the trial judge (1) properly entered judgment on Bank's statutory claim in the amount of the wrongfully midirected payments; but (2) erred in denying the bank's motion for partial judgment notwithstanding the verdict with respect to the final two checks, as there was insufficient evidence to support Construction Company's defense of estoppel. View "Reading Coop. Bank v. Constr. Co." on Justia Law

Plaintiff, HipSaver, Inc., was a Massachusetts corporation engaged in the design, manufacture, and sale of hip protectors. In 2007, the Journal of the American Medical Association (JAMA) published an article authored in part by Defendant, an associate professor at Harvard Medical School, that concluded based on the results of a clinical trial that hip protectors were "not effective in nursing home populations." HipSaver filed a complaint against Defendant, claiming that Defendant had disparaged HipSaver's product in the JAMA article and was liable for monetary damages. The trial judge granted Defendant's motion for summary judgment and dismissed HipSaver's complaint. The Supreme Court affirmed, holding that summary judgment was properly entered for Defendant where HipSaver failed to demonstrate that it had a reasonable expectation of proving all of the essential elements of a cause of action for commercial disparagement. View "HipSaver, Inc. v. Kiel" on Justia Law

Father of a sixteen-year-old daughter filed a complaint for protection under Mass. Gen. Laws ch. 209A against Defendant, a twenty-four-year-old man, seeking to prevent his daughter from voluntarily engaging in a sexual relationship with Defendant. Defendant was served with the ex parte abuse prevention order. Following a hearing before a district court judge, the order was extended for one year. Defendant appealed, asserting that the evidence was insufficient to support a finding of abuse and that the order should not have been extended because he and Plaintiff were not in a substantive dating relationship. The Supreme Court vacated the extension order, holding that there was no basis for the judge to conclude that Defendant's conduct rose to the level of "abuse" as required by the statute. View "E.C.O. v. Compton" on Justia Law

Mother and Father were divorced by a judgment of divorce dated 2008 that granted shared legal custody of the parties' child and physical custody to Mother. The judgment included an order directing Father to pay child support to Mother. In 2009, Mother filed a complaint for modification of the child support order, claiming that Father's promotion and increased salary had changed the circumstances underlying the original support order. The trial judge dismissed the modification complaint, finding that the increase in Father's income was not a material and substantial change of circumstances and that no modification was warranted. The appeals court affirmed. The Supreme Court reversed, concluding that the trial judge erred in applying a standard requiring a material and substantial change in circumstances rather than the standard set forth in Mass. Gen. Laws ch. 208, 28, which provides that a child support order shall be modified if there is an inconsistency between the amount of the existing order and the amount that would result from application of the Massachusetts Child Support Guidelines. Remanded for consideration of the modification request under the statutory inconsistency standard. View "Morales v. Morales" on Justia Law