Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of kidnapping, assault by means of a dangerous weapon, assault and battery causing serious bodily injury, assault and battery, and malicious destruction of property. The court of appeals affirmed. The Supreme Court reversed Defendant's conviction of assault and battery causing serious bodily injury, holding that the evidence, which consisted primarily of medical records not explained by an expert witness, was insufficient to permit a rational jury to find that the victim suffered "serious bodily injury" within the meaning of the relevant statute. Remanded for resentencing on the remaining convictions. View "Commonwealth v. Scott" on Justia Law

While serving a period of probation for unrelated convictions, Defendant allegedly sold crack cocaine to a confidential police informant. Prior to his probation revocation hearing, Defendant moved for disclosure of the informant's identity. The district court denied the motion. The court then revoked Defendant's probation for violation of the terms of probation. At issue on appeal was whether a defendant facing probation revocation due to an alleged new criminal offense is entitled to disclosure of the identity of an informant who was a participant in the alleged offense, the only nongovernment witness to the offense, and the only percipient witness to the entire alleged transaction. The Supreme Court vacated the district court's judgment, holding (1) under such circumstances, disclosure may be appropriate; and (2) the district court erred in denying Defendant's motion for disclosure on the ground that disclosure is never required in probation revocation proceedings. View "Commonwealth v. Kelsey" on Justia Law

Defendant was on parole from his prison sentence for armed robbery and on probation for his conviction of rape of a child when, one evening, his parole officer investigated a possible violation of her directive that Defendant remain home on Halloween to avoid congregating with children who were out trick-or-treating. When the parole officer discovered Defendant was not where he claimed to be that evening, Defendant's parole was revoked and his probation terminated. Defendant was subsequently indicted for misleading a parole officer with the intent to obstruct a criminal proceeding. The evidence at trial revealed that, on the night at issue, Defendant went to his paramour's apartment while her children were present. The trial court convicted Defendant of the charge. The Supreme Court affirmed, holding that it is a crime under Mass. Gen. Laws ch. 268, 13B for a parolee to mislead a parole officer who is investigating the parolee's possible future to comply with parole conditions, and it does not matter that the parolee failed to succeed in misleading the parole officer. View "Commonwealth v. Figueroa" on Justia Law

This case involved two litigations in which directors-shareholders asserted claims against a closely-held corporation and its directors. The first litigation, brought in 2007, settled, and the instant lawsuit arose out of an alleged violation of the settlement agreement. The case came before the Supreme Court on an interlocutory appeal from an order requiring the corporation to produce documents described in the Plaintiffs' subpoena. At issue on appeal was whether the corporation and its corporate counsel and accountants could assert attorney-client privilege or work product protection against the directors-shareholders. The Supreme Court vacated the order for the production of documents to the extent that it implicated privileged or work-product protect material as related to the 2007 and present litigations, holding that, because there was sufficient evidence that Plaintiffs' interests were adverse to the interests of the corporation as concerned the litigations, Plaintiffs were not entitled to privileged or protected information relating to the two litigations. View "Chambers v. Gold Medal Bakery, Inc." on Justia Law

After a jury trial, Defendant was convicted of manslaughter. The principal question on appeal was whether, during a trial where the defendant raises a claim of self-defense and, pursuant to Commonwealth v. Adjutant, has been permitted to introduce evidence of the victim's prior violent acts on the issue of the identity of the first aggressor, the Commonwealth may introduce evidence of the defendant's prior violent acts on that same issue, to be followed by an instruction that the jury may consider the evidence of both parties' violent acts on the findings of who was the first aggressor. The Supreme Court answered yes, provided that the Commonwealth gives the defendant notice appropriately in advance of its intent to introduce such evidence and the trial judge determines that introduction of such evidence is more probative of its intended purpose than prejudicial to the defendant. In so answering, the Court affirmed the judgment of the trial court. View "Commonwealth v. Morales" on Justia Law

In 2003, Plaintiffs filed a complaint against a police officer and city, alleging that, in 1999, the officer entered Plaintiffs' convenience store, arrested two of the plaintiffs, and beat all of the plaintiffs. Two of the plaintiffs were acquitted of criminal charges, but, in the meantime, Plaintiffs lost their business and suffered physical and emotional injuries. More than thirteen years after the incident and after a "tortuous" procedural history, the case arrived at the Supreme Court on limited further appellate review. In Jones II, the appeals court ordered the reinstatement of a 2004 default judgment against Defendants. The Court also had before it on direct appellate review an order of the superior court that amended the 2004 default judgment to correct a clerical error and that reinstated it. The Supreme Court (1) vacated the default judgment and remanded the matter for further proceedings to assess damages, holding that, under the circumstances here, a remand was necessary; and (2) vacated the amended judgment, holding that the superior court did not have jurisdiction to entertain a motion to amend the earlier default judgment, even to correct a clerical mistake, at the time the motion judge acted in 2012. View "Jones v. Boykan" on Justia Law

In 2010, a criminal complaint was filed in the district court charging Defendant with the commission of an armed robbery that took place in 2000. More than ten years after the date of the armed robbery, a grand jury returned an indictment against Defendant for that offense. The superior court dismissed the case with prejudice, concluding that the statute of limitations required an indictment to be issued and filed within ten years from the date of the offense. The Supreme Court affirmed, holding (1) the relevant statute requires the filing of an indictment within the ten-year limitations period for armed robbery; and (2) the filing of a complaint within the limitations period, and the return of an indictment outside of that period, does not constitute timely commencement of the criminal proceeding. View "Commonwealth v. Perella" on Justia Law

Two sets of plaintiffs brought actions against the city of Worcester, alleging that the city was liable to them for nuisance, continuing nuisance, and continuing trespass arising from the discharge of effluent from the city's sewer system onto their properties. After the lower courts made a series of rulings in favor of the city, Plaintiffs appealed. The Supreme Court held (1) Plaintiffs' nuisance claims were not barred because they failed to satisfy the presentment requirement of the Massachusetts Tort Claims Act, as application of the presentment requirement in these cases would be egregiously unfair to Plaintiffs given that the law did not require presentment of nuisance claims at the time they filed their lawsuits; and (2) none of the statutory exceptions to sovereign immunity by the city was applicable in this case, and the city remained subject to suit. Remanded. View "Shapiro v. City of Worcester" on Justia Law

In 1995, Defendant was charged with assault and battery by means of a dangerous weapon and indecent assault and battery on a child under the age of fourteen. At the time, Defendant was a minor and primarily spoke Khmai. During his plea colloquy, Defendant admitted to sufficient facts and was placed on probation. Defendant was committed to the Department of Youth Services after he violated the terms of his probation. In 2009, as an adult, Defendant sought to vacate his pleas, asserting he did not knowingly and voluntarily admit to sufficient facts where no interpreter was present during his plea colloquy and where he was denied effective assistance of counsel. The juvenile court denied Defendant's motion for a new trial, and the appeals court affirmed. The Supreme Court affirmed, holding that Defendant did not provide sufficient evidence to rebut the presumption of regularity of his plea proceedings and did not demonstrate he was denied the effective assistance of counsel. View "Commonwealth v. Yardley Y." on Justia Law

Defendant had a license permitting him to carry a firearm for all lawful purposes. After driving to work one day, Defendant attempted to obtain a gun locker key for the storage of his firearm during his work shift, but all the lockers were full. Consequently, Defendant placed his gun in his vehicle's glove box and locked the vehicle. Defendant's car was later searched, and Defendant was charged with firearms violations. After a jury trial, Defendant was convicted of improperly carrying a firearm in a motor vehicle in violation of the carrying statute and unlawfully storing a firearm in violation of the storage statute. The Supreme Court reversed, holding (1) the evidence was insufficient to support Defendant's conviction under the carrying statute, and Defendant was entitled to a directed verdict of not guilty on that charge; and (2) because the trial judge did not properly instruct the jury regarding what qualifies as a locked container, Defendant's conviction under the storage statute was reversed and the case remanded for a new trial on that charge. View "Commonwealth v. Reyes" on Justia Law