Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court held that, under the circumstances of the underlying case, the Graves Amendment, 49 U.S.C. 30106, protected an automobile dealership from being held vicariously liable for the tortious conduct of the driver of its courtesy vehicle.An automobile dealership based in New Jersey provided a courtesy vehicle to a customer while it serviced the customer's vehicle in its automobile service center. Contrary to the terms of the courtesy vehicle agreements, the customer drove the vehicle beyond the permitted radius of travel and into the Commonwealth, where the vehicle struck one of the plaintiffs, causing serious injuries. Plaintiffs brought a negligence action against the dealership and the customer. The superior court granted summary judgment for Defendants, concluding that the dealership, as the owner of the courtesy vehicle, was presumptively vicariously liable for the injuries caused by the customer's wife. The Supreme Judicial Court affirmed the judgment for the dealership and vacated the judgment for the customer, holding (1) the Graves Amendment protected the dealership from liability in this case; and (2) there was a dispute of material fact as to the negligent entrustment claim against the customer. View "Garcia v. Steele" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of murder in the first degree and remanded this case for further proceedings, holding that the trial justice erred when he failed to instruct the jury on the impact of mental impairment and intoxication on whether Defendant acted in a cruel or atrocious manner, and this error created a substantial likelihood of a miscarriage of justice.Following a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty for the death of a woman who died from multiple chop wounds from a machete. On appeal from the denial of his motion for a new trial, Defendant argued that the trial justice erred by failing to provide two jury instructions regarding mitigating circumstances. The Supreme Judicial Court vacated Defendant's conviction, holding that the trial justice did not err by omitting Defendant's requested instructions on sudden combat but did err in failing to give an instruction on mental impairment as it related to extreme atrocity or cruelty, and the error created a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Miranda" on Justia Law

The Supreme Judicial Court affirmed the judgment of the juvenile court denying the Commonwealth's motion to revise Juvenile's sentence in this case, holding that a juvenile court judge may commit a youthful offender to the custody of the Department of Youth Services (DYS) until his twenty-first birthday and then suspend that commitment with conditions of probation.Pursuant to a plea agreement, the juvenile court judge adjudicated Juvenile to be a youthful offender. The judge ordered Juvenile committed to DYS until he reached the age of twenty-one and then suspended the commitment with conditions of probation until the day before Juvenile's twenty-first birthday. The Commonwealth moved for a revision of Juvenile's sentence, challenging the judge's decision to suspend Juvenile's commitment to DYS and to place him on probation, but the judge denied the motion. The Supreme Judicial Court affirmed, holding that the juvenile was within his discretion in suspending Juvenile's commitment pursuant to Mass. Gen. Laws ch. 276, 87. View "Commonwealth v. Dones" on Justia Law

The Supreme Judicial Court reversed the decision of the superior court granting summary judgment in favor of Defendant in this age discrimination action, holding that Plaintiff produced sufficient evidence to create a dispute of fact regarding whether he was terminated due to discriminatory animus.Plaintiff sued Defendant, his former employer, after he was laid off in a reduction in force. The superior court granted summary judgment in favor of Defendant, determining that Plaintiff could not show that Defendant's stated justification for his termination was pretextual. The appeals court reversed. The Supreme Judicial Court remanded the case to the superior court for further proceedings, holding that Plaintiff produced evidence from which a jury could find that he was selected for the reduction in force as part of a corporate strategy to lay off older workers. View "Adams v. Schneider Electric USA" on Justia Law

The Supreme Judicial Court vacated Defendant's convictions for five counts of trafficking a person for sexual servitude and a second and subsequent offense of possession of a class A substance with intent to distribute, holding that the conflict of interest inherent in counsel's bigotry against persons of Defendant's faith and race deprived Defendant of his right to effective assistance of counsel.Defendant, a Black man of the Muslim faith, was appointed counsel who openly shared his hatred of and bigotry against people of the Muslim faith and his racism against Black persons. Counsel advised Defendant to accept a plea deal, which Defendant did. Defendant later filed a motion to withdraw his guilty plea and for a new trial, arguing that his counsel had an actual conflict of interest. The motion judge denied the motion. The Supreme Judicial Court reversed and remanded the case for a new trial, holding that Defendant met his burden to establish that counsel's representation of him was impaired by an actual conflict of interest. View "Commonwealth v. Dew" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of carrying a firearm without a license and his sentence of eighteen months in a house of correction, holding that the Commonwealth did not demonstrate beyond a reasonable doubt that Defendant knowingly, intelligently, and voluntarily waived his Miranda rights, and Defendant did not waive this issue.In a pretrial motion, Defendant filed a motion to suppress based on the alleged inadequacy of the Miranda warnings provided to him in Spanish. The motion judge denied the motion after finding that Defendant was given "the full complement of Miranda warnings" in English and in Spanish. After he was convicted and the convictions were affirmed on appeal Defendant filed a postconviction motion for a new trial, which the motion judge denied following a hearing. The appeals court affirmed. The Supreme Judicial Court vacated the conviction, holding (1) Defendant did not waive the issue of whether Miranda warnings were properly given to him in Spanish; and (2) the admission of Defendant's post arrest statements was error. View "Commonwealth v. Delossantos" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of voluntary manslaughter and his sentence of ten to twelve years in prison, holding that the trial errors detected in the underlying proceedings did not, either individually or in combination, create a substantial risk of a miscarriage of justice.Defendant was charged with murder in the first degree and, after a jury trial, convicted of the lesser charge of voluntary manslaughter. On appeal, Defendant argued that rap lyrics he had written were erroneously admitted at trial, that the Commonwealth improperly commented on his rearrest silence, that one of the deliberating jurors was not fair and impartial, and that the jury instructions misstated the law on self-defense. The Supreme Judicial Court affirmed, holding (1) there was error in the trial court's decision to admit Defendant's lyrics, but Defendant was not prejudiced; (2) referencing Defendant's pre-arrest silence was error, but there was no substantial likelihood of miscarriage of justice; but (3) in the context of the entire trial, there was no substantial risk of a miscarriage of justice. View "Commonwealth v. Correia" on Justia Law

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