Justia Massachusetts Supreme Court Opinion Summaries

In this case involving a facility that operated under the protection of a thirty-six-year-old consent decree the Supreme Judicial Court held that the trial judge did not abuse her discretion in concluding that the Department of Developmental Services failed to establish that the consent decree should be terminated based on the evidentiary record before the probate court.In question was the treatment and welfare of individuals who suffered from severe developmental and intellectual disabilities that caused them to engage in grievous self-harm and other life-threatening behaviors. The individuals lived in group homes under the care of Judge Rotenberg Educational Center, Inc. (JRC), a facility that employed the use of aversive interventions such as electric skin shock as part of its treatment approach. In the 1980s and 1990s State agencies disrupted JRC's operations, after which the consent decree was issued. Years later, the agencies bound by the decree moved for its termination, but the probate and family court denied the motion. The Supreme Judicial Court affirmed, holding that the Department's arguments against continued enforcement of the consent decree were unavailing. View "Judge Rotenberg Educational Center, Inc. v. Commissioner of Dep't of Developmental Services" on Justia Law

The Supreme Judicial Court held that the Secretary of the Commonwealth did not overstep the bounds of the authority granted to him under the Massachusetts Uniform Securities Act (MUSA), Mass. Gen. Laws ch. 110A, by promulgating the "fiduciary duty rule."The Secretary brought an administrative enforcement proceeding alleging that Plaintiff Robinhood Financial LLC violated the prohibition in Mass. Gen. Laws ch. 110A, 204(a)(2)(G) against "unethical or dishonest conduct or practices in the securities, commodities or insurance business" by dispensing ill-suited investment advice to unsophisticated investors. The Secretary defined the phrase in section 204(a)(2)(G) to require broker-dealers that provide investment advice to retail customers to comply with a statutorily-defined fiduciary duty. Thereafter, Plaintiff brought the instant action challenging the validity of the fiduciary duty rule. The superior court concluded that the Secretary acted ultra vires to promulgating the rule. The Supreme Judicial Court reversed, holding (1) the Secretary acted within his authority under MUSA; (2) the fiduciary rule does not override common-law protections available to investors; (3) MUSA is not an impermissible delegation of legislative power; and (4) the fiduciary rule is not invalid under the doctrine of conflict preemption. View "Robinhood Financial LLC v. Secretary of the Commonwealth" on Justia Law

The Supreme Judicial Court vacated the decree and order of the superior court in this probate action, holding that there existed a genuine issue of material fact precluding the grant of partial summary judgment.The decedent's will left her entire estate to a testamentary trust for the benefit of her dog, Licorice, and any other pet she might have at the time of her death. At the time of her death, however, no pet survived the decedent. Under the terms of the trust, the trustees were required to designate a charity to receive the remainder of funds in the trustees' control after the death of all beneficiaries. At issue was whether the remainder of the decedent's estate to charity was valid despite Licorice having predeceased the decent or whether Licorice's failure to survive the decedent rendered the pet trust void. On partial summary judgment, the judge held that the pet trust provision failed because Licorice predeceased the decedent. The Supreme Judicial Court remanded the case, holding that the provisions for Licorice in the testamentary trust lapsed, leaving a genuine issue of material fact whether there was a clear intention that the charitable remainder not be conditioned on Licorice's survival of the decedent. View "In re Estate of Jablonski" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court judge granting summary judgment in favor of BSC Companies, Inc., BSC Group, Inc., and the companies' president (collectively, BSC) in this action brought by BSC's former employees alleging claims under the Prevailing Wage Act, Mass. Gen. Laws ch. 149, 26-27H, holding that the contracts at issue were not governed by the Act, and BSC was not required to pay its employees a prevailing wage pursuant to the contracts.At issue were two professional engineering services contracts awarded by the Department of Transportation (MassDOT) to BSC. The contracts were not competitively bid and were not awarded to the lowest bidder, unlike contracts for public works construction projects governed by the Act. Further, the contracts did not specify that BSC's employees would be paid at least a prevailing wage determined by the Department of Labor Standards. The superior court judge granted summary judgment to BSC. The Supreme Court affirmed, holding that Plaintiffs were not entitled to a prevailing wage for their work under the professional services contracts. View "Metcalf v. BSC Group, Inc." on Justia Law

The Supreme Judicial Court affirmed the order of the superior court granting summary judgment in favor of Defendant in this negligence action brought by Plaintiff seeking damages for wrongful death and loss of consortium, holding that summary judgment was appropriately granted in favor of Defendant.Drake Scott, Jr. was shot and killed outside the exit door of a nightclub leasing space in a commercial property. Plaintiff, Scott's mother, filed this negligence action against the owner of the property, alleging that Defendant knew or should have known about potential dangers and threat of violence on the property and that Defendant breached this duty, resulting in Scott's death. The trial judge allowed Defendant's motion for summary judgment, concluding that the shooting was not foreseeable, and therefore, Defendant owed no duty to protect Scott. The Supreme Judicial Court affirmed, holding the the shooting that occurred in this case was not reasonably foreseeable to Defendant, and therefore, Defendant had no legal duty to prevent it. View "Hill-Junious v. UTP Realty, LLC" on Justia Law

The Supreme Judicial Court affirmed the judgment of the district court denying Defendants' motion to dismiss Plaintiff's action alleging that defendant Massachusetts Coastal Railroad LLC (MCR) paid him less than the prevailing wage on State public works projects, holding that the trial court did not err.In their motion to dismiss, MCR and its managing officer (together, Defendants), argued that the Interstate Commerce Commission Termination Act, 49 U.S.C. 10501 preempted the Prevailing Wage Act, Mass. Gen. Laws ch. 149, 26-27H, and therefore, the Commonwealth was precluded from enforcing the Act. The Supreme Judicial Court disagreed and affirmed, holding (1) Defendants failed to show that the Prevailing Wage Act was preempted; and (2) Plaintiff's allegations plausibly suggested a right to relief under the Act. View "Marsh v. Mass. Coastal Railroad LLC" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the second degree and assault and battery by discharge of a firearm but vacated his convictions for carrying a firearm without a license and carrying a loaded firearm without a license, holding that the trial judge's failure to instruct the jury that the Commonwealth was required to prove an absence of a valid license created a substantial risk of a miscarriage of justice.At trial, Defendant sought to introduce Adjutant evidence or evidence of specific incidents of violence allegedly initiated by the victim. The trial judge allowed Defendant to introduce limited evidence of violent incidents initiated by the victim. The Supreme Judicial Court vacated Defendant's convictions in part, holding (1) the judge's ruling excluding additional testimony about the violent instances initiated by the victim exceeded the cope and purpose of Adjutant evidence, but there was no prejudice from its exclusion; (2) the trial judge did not err in the instruction regarding the jury's consideration of Adjutant evidence; and (3) pursuant to this Court's decision in Commonwealth v. Guardado, 491 Mass. 666 (2023), Defendant's firearm convictions must be vacated because the judge's failure to properly instruct the jury that Defendant did not have a license to carry a firearm was not harmless. View "Commonwealth v. Souza" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of two counts of murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder on a theory of joint venture and other crimes, holding that Defendant was not entitled to relief on her allegations of error.Specifically, the Supreme Judicial Court held (1) the trial judge did not err in denying Defendant's motion for change of venue, and Defendant failed to show any actual juror prejudice from the denial or that she was tried by anything but a fair and impartial jury; (2) the evidence was sufficient to prove Defendant's guilt as a joint venturer of murder in the first degree of the first victim; (3) there was also sufficient evidence to support Defendant's conviction of the first victim on the basis of felony murder; and (4) there was ample evidence to prove Defendant's guilt as a joint venturer of murder in the first degree on the basis of deliberate premeditation of the second victim. View "Commonwealth v. Smith" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of assault and battery by means of a dangerous weapon, holding that portions of the victim's then-girlfriend's grand jury testimony were properly admitted in accordance with the hearsay exemption for prior inconsistent statements.Prior to trial, the victim's then-girlfriend Shyla Bizarro identified Defendant as the victim's attacker from surveillance video footage and testified to her identification before the grand jury. Prior to her testimony, however, Bizarro revealed that she wished to recant her statements to police and her grand jury testimony. The trial judge admitted substantively the recanted portions of Bizarro's grand jury testimony, including her prior statements of identification. The Supreme Judicial Court affirmed the conviction, holding (1) the portions of Bizarro's grand jury testimony were properly admitted as prior inconsistent statements; (2) portions of Bizarro's grand jury testimony identifying Defendant in the video independently satisfied the hearsay exemption for statements of identification; and (3) there was no merit to Defendant's remaining arguments. View "Commonwealth v. Brum" on Justia Law

The Supreme Judicial Court vacated Defendant's firearm-related convictions but affirmed his convictions for murder in the first degree based on a theory of felony-murder, home invasion and armed assault with intent to rob, holding that the firearm-related convictions must be vacated in light of Commonwealth v. Guardado, 491 Mass. 666 (2023).Specifically, the Supreme Judicial Court held (1) trial counsel was not ineffective for failing to introduce certain categories of telephone calls; (2) there was no error in the denial of Defendant's motion for a new trial; (3) Defendant's convictions of unlawful possession of a firearm and unlawful possession of a loaded firearm must be vacated in light of this Court's precedent decision in Guardado; and (4) there was no reason for this Court to exercise its extraordinary authority pursuant to Mass. Gen. Laws ch. 278, 33E to grant Defendant a new trial or reduce the murder conviction to a lesser degree of guilt. View "Commonwealth v. Gibson" on Justia Law