Justia Massachusetts Supreme Court Opinion Summaries

Employees of Michaels Stores, Inc. request and record customers' zip codes in processing credit card transactions. Plaintiff, a customer of Michaels, filed an action on behalf of herself and a putative class of Michaels customers in the federal district court, alleging that Michaels unlawfully writes customers' personal identification information on credit card transaction forms in violation of Mass. Gen. Laws ch. 93, 105(a) (the statute). The Supreme Court accepted certification to answer questions of state law and held (1) a zip code constitutes personal identification information for purposes of the statute; (2) a plaintiff may bring an action for violation of the statute absent identity fraud; and (3) the term "credit card transaction form" in the statute refers equally to electronic and paper transaction forms. View "Tyler v. Michael Stores, Inc." on Justia Law

Premier Capital, LLC was in the business of debt acquisition, management, and collection. On July 3, 2007, Premier filed an action in the superior court alleging that it was the current holder of a sealed promissory note from Max Zeller Furs, Inc., executed on September 10, 1987, and that KMZ, Inc. was liable on the note as the successor in interest. The superior court granted summary judgment for KMZ on the ground that Premier's complaint was not timely filed under the six-year statute of limitations set forth in Mass. Gen. Laws ch. 106, 3-118. The Supreme Court reversed, holding (1) although the statute does apply to actions on a sealed promissory note, it only applies to causes of action accruing after its enactment in 1998; and (2) because Premier's cause of action accrued before the statute was enacted, and the note upon which Premier filed suit was executed under seal, Premier timely commenced its action against KMZ under the twenty-year statute of limitations governing actions on contracts under seal set forth in Mass. Gen. Laws ch. 260, 1. Remanded. View "Premier Capital, LLC v. KMZ, Inc." on Justia Law

Petitioner sought release from commitment as a sexually dangerous person. After being found indigent, Petitioner filed a motion requesting that the judge authorize funds to retain the services of an independent qualified examiner to evaluate Petitioner and to assist in the preparation of his case. The judge approved the motion for funds in the amount of $2,500. Petitioner subsequently retained a licensed psychologist who agreed to conduct an evaluation of Petitioner and to testify at trial at the hourly rate approved by the Committee for Public Counsel Services (CPCS): $190 an hour. After trial, Petitioner moved for the authorization of an additional $2,060 to compensate the psychologist. The trial judge allowed the motion in the amount of $1,500. The appeals court denied Petitioner's appeal, concluding that the judge did not err in limiting the expert's compensation to $4,000, which was "reasonable under the circumstances." The Supreme Court affirmed, holding (1) a judge is bound by CPCS's determination of an hourly rate but still retains the authority to determine whether the total amount billed is reasonable; and (2) the judge in this case acted in accordance with these limits in determining the reasonable amount of the expert's fee. View "In re Edwards" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. Defendant appealed, arguing that the trial court erred in denying his motion to suppress statements he made to police and his motion for a new trial. The Supreme Court affirmed, holding (1) the motion judge did not err in denying Defendant's motion to suppress and concluding that the Commonwealth satisfied its burden of proving beyond a reasonable doubt that Defendant made a knowing, willing, and intelligent waiver of his Miranda rights and that his statements were otherwise voluntarily made; and (2) the motion judge did not err in denying Defendant's motion for a new trial on the ground that his trial counsel provided ineffective assistance by failing to file a pretrial motion to suppress a witness's identification of Defendant, as Defendant failed to demonstrate a likelihood that a motion to suppress this evidence would have been successful. View "Commonwealth v. Jules" on Justia Law

Plaintiff was employed by the City in 1983 and was discharged from his employment in 2007. At the time of his departure, Plaintiff had accrued fifty days of unused vacation time. Plaintiff was not paid for those vacation days on the day of his termination. Plaintiff filed an action alleging that the City violated the Wage Act when it failed to pay him for his accrued vacation days on the day he was terminated. The superior court dismissed Plaintiff's claim, finding that although the manner of the City's payments to Plaintiff violated the express language of the Wage Act, the City nevertheless compensation Plaintiff. The Supreme Court reversed, holding that the City could not cast its payments to Plaintiff as vacation pay after the fact and that Plaintiff was entitled to recover his vacation pay in addition to costs and attorney's fees. View "Dixon v. City of Malden" on Justia Law

Defendant was convicted of murder in the first degree, armed assault with intent to murder, and two counts of illegal possession of a firearm. The Supreme Court affirmed the convictions, holding (1) the trial judge did not err in limiting cross-examination of the Commonwealth's principal witness; (2) the trial court did not err in admitting a police officer's testimony, which, contrary to Defendant's assertion, did not improperly vouch for the principal witness's testimony; (3) the trial judge did not err in declining to sequester the police witnesses who were involved in the investigation and who had conducted interviews of the principal witness; and (4) the prosecutor did not improperly vouch for Commonwealth witnesses or misstate evidence during his closing argument. View "Commonwealth v. Ahart" on Justia Law

Defendant filed a document in the county court entitled "Defendant-Appellant's Interlocutory Appeal on Confrontation Clause With a Known Confidential Informant - Sixth Amendment" that was not accompanied by copies of any relevant papers from the criminal case pending against Defendant in the district court. A single justice of the Supreme Court denied relief without a hearing. The full Supreme Court affirmed, holding that Defendant failed to meet his most basic obligations as an appellant in the full court because, among other things, his brief failed to contain adequate appellate argument, and his record appendix contained numerous items that were not before the single justice. View "Azubuko v. Commonwealth" on Justia Law

When Plaintiff became the subject of a federal indictment, the school department (Defendant) suspended her without pay from her position as a school adjustment counselor. Ultimately, the indictment was dismissed. Plaintiff sought reinstatement to her position, but Defendant terminated her employment. Plaintiff filed a grievance challenging the termination, and an arbitrator ordered that she be reinstated. Plaintiff then filed an action seeking confirmation of the arbitration award and back pay for the period of her suspension an the period between her termination and reinstatement. The superior court affirmed the arbitration award but granted summary judgment in favor of Defendant with respect to Plaintiff's back pay claims. The appeals court affirmed the denial of back pay with respect to the period between Plaintiff's termination and reinstatement but reversed with respect to the period of her suspension. The Supreme Court affirmed. Remanded. View "Serrazina v. Springfield Pub. Schs." on Justia Law

Defendant was indicted for aggravated rape, indecent assault and battery, and other related offenses. The charges were based on five separate incidents involving five female victims. During the pretrial proceedings, the Commonwealth provided discovery to Defendant that included records related to medical treatment that some of the alleged victims received following the incidents. Defendant subsequently filed a motion for discovery that included the request for additional medical treatment or follow up visits any victim had pertaining to the indicted offenses. The superior court allowed the motion with respect to any follow up medical visits. The Commonwealth sought relief from that order, arguing that the order was improper because it required the Commonwealth to inquire of the alleged victims whether they sought or had follow-up treatment. The Supreme Court affirmed, concluding that the judge was only allowing Defendant's request to the extent it required the Commonwealth to provide information in its possession. View "Commonwealth v. Castillo" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. Defendant appealed, arguing error in the admission of evidence, the prosecutor's closing argument, and the judge's instructions to the jury. The Supreme Court affirmed, holding (1) the trial court did not palpably err in admitting a 911 recording of the victim stating three times, "I've been stabbed"; (2) the prosecutor did not improperly attempt to evoke sympathy from the jury by playing, during his closing argument, the 911 recording; and (3) the trial court did not prejudicially err in its instructions to the jury on self-defense. View "Commonwealth v. Harris" on Justia Law