Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court vacated the judgment of the trial court dismissing FCA US LLC from the underlying tort lawsuit, holding that Massachusetts had personal jurisdiction over FCA US under the Commonwealth's long-arm statute, Mass. Gen. Laws ch. 223A, 3, and the due process clause of the Fourteenth Amendment.Paul Doucet was the passenger in a car that was involved in an accident in New Hampshire, rendering him incapacitated. Doucet's guardians filed suit against FCA US, the vehicle's manufacturer, and the Massachusetts distributor-dealership Sudbay Chrysler Dodge, Inc. FCA US, a Delaware limited liability company with its principal place of business in Michigan, filed a motion to dismiss for want of personal jurisdiction. The trial judge granted the motion and dismissed FCA US as a party to the case, concluding that Massachusetts lacked personal jurisdiction under both the long-arm statute and the due process clause of the United States Constitution. The Supreme Judicial Court vacated the judgment below, holding that personal jurisdiction existed in Massachusetts over FCA US for the underlying claims pursuant to both the Commonwealth's long-arm statute and the Fourteenth Amendment's due process clause. View "Doucet v. FCA US LLC" on Justia Law

The Supreme Judicial Court remanded this matter involving the decision of the Planning Board of Monterey to deny Appellant's application to build an RV camp on the grounds of its Monterey property on the basis that the RV camp would not be an exempt religious use under the terms of the Dover Amendment, Mass. Gen. Laws ch. 40A, 3, holding that the proposed RV park would be an exempt religious use.Appellant, a nonprofit Christian organization that operated a camp in Monterey providing chapel sessions and religious instruction, applied to build an RV camp on the grounds of its property to house families who attend camp sessions. The Board denied the application, concluding that the RV camp was not a customary religious use and should not fall under the umbrella of the Dover Amendment. The Supreme Court remanded the case, holding (1) the primary or dominant purpose of the trailer park was a religiously significant goal; and (2) therefore, the proposed RV camp would be an exempt use under the Dover Amendment. View "Hume Lake Christian Camps, Inc. v. Planning Bd. of Monterey" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of both deliberate premeditation and extreme atrocity or cruelty, holding that there was no error in the underlying proceedings or in the verdict.On appeal, Defendant argued, among other things, that the district court erred in denying his motion to suppress the evidence recovered pursuant to a search warrant following a police trooper's examination of Defendant's vehicle, which was visibly parked in the driveway leading up to his house. The Supreme Judicial Court affirmed, holding (1) because Defendant's vehicle was not parked within the curtilage of his home the trooper's observations of the vehicle did not constitute a search for constitutional purposes; and (2) there was no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial. View "Commonwealth v. Wittey" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of deliberate premeditation but vacated his conviction of murder in the first degree on a theory of felony-murder, holding that the felony-murder conviction was improper.Defendant was convicted of murder in the first degree on theories of deliberate premeditation and felony-murder, with aggravated kidnapping as the predicate felony. In this appeal, consolidated with the appeal of his motions for a new trial and for reconsideration, Defendant argued, and the Commonwealth conceded, that the conviction of murder in the first degree on a theory of felony-murder was improper because the predicate felony of aggravated kidnapping did not exist at the time of the killing. The Supreme Court vacated Defendant's felony-murder conviction and otherwise affirmed, holding (1) Defendant's conviction of felony-murder lacked sufficient evidence to support it; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Samia" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner was awarded monetary damages after a jury trial on a breach of contract claim against Respondent. The appellate division affirmed. Petitioner later moved for the appointment of a special process server to conduct a sale of Respondent's real property in order to satisfy the amended judgment and execution. Thereafter, Respondent presented a check for the execution amount plus postjudgment interest. Petitioner refused to accept payment and continued to litigate its motion. A judge declined to take action and ordered that further accrual of postjudgment interest would be tolled. Petitioner moved to vacate the judge's tolling ruling, but the trial court declined to rule on the motion. Petitioner then filed this petition requesting relief from the tolling order. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that Petitioner was not entitled to relief. View "Suburban Electric Contracting, Inc. v. Ozdemir" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying the Commonwealth's petition filed under Mass. Gen. Laws ch. 211, 3 seeking relief from a superior court judge's denial of the Commonwealth's motion to disqualify Rosemary Scapicchio, Defendant's appellate counsel, on the ground that she had a conflict of interest, holding that the single justice did not err or abuse his discretion in denying the motion.Defendant was convicted of murder in the first degree. Later, represented by Scapicchio, Defendant filed a motion for a new trial alleging ineffective of counsel. Thereafter, Scapicchio represented Michael Barros at a hearing in an unrelated criminal case. The Commonwealth moved to disqualify Scapicchio on the grounds that her representation of both Defendant and Barros gave rise to a conflict of interest. The superior court denied the motion. The Commonwealth then filed the petition at issue. The single justice denied relief without reaching its merits. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused his discretion by denying the petition. View "Commonwealth v. Monteiro" on Justia Law

The Supreme Judicial Court affirmed the order of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that nothing in Petitioner's petition required exercise of the court's extraordinary power of general superintendence.Petitioner, who was indicted for murder in the first degree and related offenses, filed a document entitled "Notice of Default and Opportunity to Cure re affidavit -- 'Writ of Quo Warranto' re Proof of Claim/Jurisdiction'" claiming that the courts of the Commonwealth lacked jurisdiction over him. The superior court judge denied the petition. Thereafter, Petitioner brought this petition seeking review. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice was warranted in denying this Mass. Gen. Laws ch. 211, 3 petition. View "Wallace v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of one count of murder in the first degree on the theories of deliberate premeditation, extreme atrocity or cruelty, and felony murder, holding that there was no prejudicial error or reason to grant relief under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in finding Defendant competent to stand trial over defense counsel's objections; (2) Defendant was not prejudiced by the jury instructions concerning the consequences of a verdict of not guilty due to lack of criminal responsibility; and (3) the jury were entitled to conclude that Defendant was criminally responsible, and this Court declines to reduce the degree of guilt, order a new trial, or grant other relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Beatty" on Justia Law

In this case considering whether an easement (2018 easement) taken by eminent domain by the Department of Transportation (MassDOT) exceeded the scope of an easement taken in 1991 by the Department of Public Works (DPW), MassDOT's predecessor in interest, with respect to Plaintiff's land in South Boston (burdened land), the Supreme Judicial Court held that summary judgment was improperly granted for MassDOT.DPW's 1991 order of taking created an easement over the burdened land for purposes of constructing a haul road. In 2017, the Massachusetts Bay Transportation Authority began planning the construction of a test track on a portion of Plaintiff's land burdened by the 1991 easement. MassDOT recorded the 2018 confirmatory order of taking and then, contending that the taking merely confirmed that rights it held under the 1991 taking, refused to pay Plaintiff any compensation. Plaintiff responded with this litigation, and the superior court judge entered summary judgment in favor of MassDOT. The Supreme Judicial Court reversed, holding (1) while the intent of the parties should not be considered when an easement is taken by eminent domain, the ordinary rules of interpretation for easements otherwise apply; and (2) because the 1991 easement was more limited in scope than the 2018 easement, summary judgment for MassDOT must be reversed. View "Smiley First, LLC v. Dep't of Transportation" on Justia Law

The Supreme Judicial Court held that a defendant who has been serving the incarcerated portion of an illegal sentence imposed by the appellate division of the superior court has the same double jeopardy protections as a defendant who has been serving the incarcerated portion of an illegal sentence imposed by a single superior court judge.Defendant was convicted of indecent assault and battery. The appellate division revised Defendant's sentence by reducing the period of incarceration on two counts to from four to six years in prison. After it was discovered that Defendant's sentence was illegal the appellate division reversed the incarcerated portion of Defendant's sentence to concurrent terms of from five to six years. Defendant filed a petition under Mass. Gen. Laws ch. 211, 3 arguing that his resentence violated common-law principles of double jeopardy. The single justice denied the petition. The Supreme Judicial Court reversed, holding (1) when sufficient time has lapsed even an illegal sentence becomes final, and double jeopardy principles preclude the State from making upward adjustments to the sentence; and (2) Defendant was entitled to judgment on his petition. View "Martin v. Commonwealth" on Justia Law