Justia Massachusetts Supreme Court Opinion Summaries

This appeal involved a dispute over property rights in a beach parcel. Two families, Plaintiffs and Defendants, owned the property upland from the beach. In 2004, Plaintiffs filed an action in the land court to quiet title, claiming they owned a fractional interest in the beach or, in the alternative, enjoyed a prescriptive easement to use it and land leading to it. Defendants claimed that Plaintiffs had no interest in the beach as it was presently located because their title interest dated to an 1841 deed that created the parcel, and the beach no longer existed as it did in 1841. The land court judge granted summary judgment for Defendants on the title claim and determined that Plaintiffs had not met their burden of establishing a prescriptive easement. The Supreme Court (1) affirmed the portion of the judgment declaring that Plaintiffs did not have title interest in the beach as it currently existed since their interest was to a beach now submerged in the Atlantic Ocean; and (2) vacated the portion of the judgment relating to the prescriptive easement claim, as the judge's findings of fact were insufficient to permit appellate review of the judgment. Remanded. View "White v. Hartigan" on Justia Law

Plaintiff received housing assistance through the Massachusetts rental voucher program. Plaintiff rented an apartment in Chelsea and received her voucher through the Chelsea Housing Authority. In 2009, Plaintiff received notice from the Authority that it was terminating her voucher because she did not report changes in family composition and in the family's income within thirty days of the change as required by the conditions of her voucher. After a hearing, the Authority's grievance panel upheld the termination. The Board of Commissioners affirmed, as did the superior court and appeals court. The Supreme Court reversed, holding (1) it was unlawful for the Authority to proceed to the grievance panel hearing without first offering Plaintiff the opportunity to engage in settlement negotiations; (2) the regulations Plaintiff was found to have violated were impermissibly vague; and (3) the grievance panel's factual findings were insufficient. Remanded. View "Rivas v. Chelsea Hous. Auth." on Justia Law

Plaintiff served as superintendent of schools in the town of North Brookfield until 2005. Plaintiff's employment contract provided that, on his retirement, Plaintiff would be reimbursed thereafter for a percentage of his health insurance premiums on an annual basis. In 2006, Plaintiff sent a request for reimbursement for a fixed percentage of the premium costs for his health insurance policy from the date of retirement. When the town refused to honor the request Plaintiff filed this action against the school committee and the town for breach of contract and specific performance of the contract. The superior court granted Plaintiff's motion for summary judgment. On appeal, Defendants argued that the obligation to reimburse Plaintiff for a percentage of his health insurance costs annually for his life signaled that Plaintiff's final employment contract was a lifetime agreement that exceeded six years in duration and therefore violated Mass. Gen. Laws 71, 41. The Supreme Court affirmed, holding that the employment contract at issue in this case was valid and enforceable even though the reimbursement clause would presumptively exceed six years, as a contract that has expired may include enforceable obligations to be performed by the parties thereafter. View "O'Neill v. Sch. Comm. of N. Brookfield" on Justia Law

Husband and Wife sought a divorce, and probate and family court judge issued a judgment of divorce providing that Husband's alimony obligation would be reduced after the parties' youngest child graduated from high school and the marital home was placed on the market. Husband moved to alter or amend the divorce judgment, including the alimony provisions of the judgment. The judge issued an order on the motion, which did not include Husband's proposals concerning reduction in alimony. Husband appealed, arguing that the judge erred by not considering Husband's potential federal tax consequences pursuant to I.R.C. 71(c)(2). The court of appeals affirmed. The Supreme Court vacated the probate and family court judge's order to the extent that the judge did not consider the uncertainty of potentially unfair tax consequences, holding that, if presented with evidence of potential tax consequences, a judge should consider those consequences when creating or modifying alimony provisions in a divorce judgment. Remanded. View "L.J.S. v. J.E.S" on Justia Law

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