Justia Massachusetts Supreme Court Opinion Summaries

The plaintiffs, former tenants of apartments owned and managed by the defendants, filed a putative class action alleging that the defendants violated Massachusetts General Laws Chapter 186, Section 15B (4) (iii) by deducting charges for "reasonable wear and tear" from tenants' security deposits. The plaintiffs also claimed that the defendants included lease provisions requiring tenants to have the premises professionally cleaned at the end of the lease, which they argued was a violation of the same statute.The case was initially filed in the Superior Court and later removed to the United States District Court for the District of Massachusetts. The plaintiffs moved for class certification, and both parties moved for summary judgment. The Federal judge denied these motions without prejudice and certified two questions to the Supreme Judicial Court of Massachusetts regarding the interpretation of the statute.The Supreme Judicial Court of Massachusetts held that a tenant's reasonable use of a property as a residence is expected to result in gradual deterioration, such as the need for painting, carpet repair, or similar refurbishment at the end of a lease. Deductions from a security deposit for such reasonable wear and tear violate the statute. Whether damage constitutes "reasonable wear and tear" is a fact-specific question depending on various circumstances, including the nature and cause of the damage, the condition of the property at the start of the lease, and the length of the occupancy.The court also held that a lease provision requiring a tenant to have the premises professionally cleaned at the end of the lease, on penalty of bearing the costs of repairs regardless of whether the damage is reasonable wear and tear, conflicts with the statute. Such a provision is void and unenforceable under Massachusetts General Laws Chapter 186, Section 15B (8). View "Peebles v. JRK Property Holdings, Inc." on Justia Law

In 2002, the defendant was convicted of two counts of first-degree murder and sentenced to two concurrent life terms without parole. Following the 2024 decision in Commonwealth v. Mattis, which deemed life without parole for emerging adults unconstitutional, the defendant, who was 19 at the time of the crimes, sought resentencing to life with parole eligibility after 15 years and correction of his mittimus to reflect time served. The Commonwealth opposed and requested a hearing to determine if the sentences should be consecutive.The trial court granted the Commonwealth's request for a hearing, prompting the defendant to seek relief under G. L. c. 211, § 3. A single justice of the Supreme Judicial Court reserved and reported the matter to the full court.The Supreme Judicial Court of Massachusetts held that double jeopardy principles do not prevent resentencing the defendant to consecutive life terms with parole eligibility after 15 years. The court reasoned that such a change would not increase the aggregate punishment, as the original sentence was life without parole. The court also determined that a resentencing hearing is necessary to decide whether the sentences should be concurrent or consecutive, as the Mattis decision did not automatically alter the defendant's sentence.Additionally, the court ruled that the defendant is entitled to credit for time already served on each of the concurrent life sentences. Therefore, even if resentenced to consecutive terms, the defendant would be immediately eligible for parole, having already served over 23 years. The case was remanded for a resentencing hearing consistent with this opinion. View "Perez v. Commonwealth" on Justia Law

Cable Matters Inc. sought a use variance from the zoning board of appeals of Northborough to build a 20,000 square foot warehouse in an industrial zoning district. The property is also within the town's groundwater protection overlay district, which does not permit warehouses. The zoning board granted the variance, and the planning board later issued a special permit with conditions, including restrictions on storage, lighting, landscaping, delivery hours, and driveway use.The plaintiffs, who live across the street from the proposed warehouse, appealed the zoning board's decision to the Superior Court, arguing they were aggrieved by the potential noise, light, vibration, odors, and loss of open space. The Superior Court judge granted summary judgment for Cable Matters, concluding that the plaintiffs lacked standing as they failed to show they were aggrieved by the zoning board's decision. The judge found that the plaintiffs' claims were speculative and not supported by credible evidence.The plaintiffs appealed to the Appeals Court, which vacated the judgment, instructing the judge to consider potential future uses of the warehouse. The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the Superior Court judge correctly assessed the plaintiffs' standing based on Cable Matters's proposed use. The court held that potential future uses unsupported by the record should not be considered in determining standing. The court affirmed the Superior Court's order dismissing the plaintiffs' complaint for lack of standing. View "Stone v. Zoning Board of Appeals of Northborough" on Justia Law

On November 4, 2015, a resident near a secluded dirt road in Worcester heard a loud bang and saw flames. Firefighters found a burning vehicle with a charred body inside, later identified as Marie Martin. An autopsy revealed a bullet in her skull. The investigation led to Donovan E. Goparian, who was indicted for murder. In 2020, a jury convicted him of first-degree murder based on deliberate premeditation. Goparian filed a motion for a new trial, arguing that the Commonwealth failed to disclose exculpatory evidence from a Federal inmate implicating a third party. The motion judge denied the request for an evidentiary hearing and did not act on the request for postconviction discovery. The motion for a new trial was also denied.The defendant appealed both his conviction and the denial of his motion for a new trial. The Massachusetts Supreme Judicial Court reviewed the case. The court found that the judge abused his discretion by denying the defendant's request for an evidentiary hearing and failing to act on the request for postconviction discovery. The court concluded that the defendant had made an adequate showing that the Commonwealth had possession, custody, or control of the exculpatory information and that its nondisclosure could have prejudiced the defendant.The Massachusetts Supreme Judicial Court vacated the order denying the motion for a new trial, reversed the order denying the request for an evidentiary hearing, and remanded the case for further proceedings. The court also ordered postconviction discovery concerning the exculpatory information and deferred plenary review of the defendant's direct appeal pending resolution of the motion for a new trial. View "Commonwealth v. Goparian" on Justia Law

The defendant was convicted of first-degree murder for the stabbing death of Carlos Ramos in the apartment of Maria Samot, a key witness who is deaf, illiterate, and severely language deprived. Samot communicates using idiosyncratic gestures rather than any recognized language. At trial, her testimony was interpreted by a team of certified deaf and ASL interpreters, but no determination was made regarding the appropriateness of these interpreters as required by Massachusetts law (G. L. c. 221, § 92A). This led to significant issues during cross-examination, where Samot provided numerous nonresponsive answers.The defendant filed a motion for a new trial, arguing that justice had not been done due to noncompliance with the statute. The motion judge, who was also the trial judge, held an evidentiary hearing where experts testified about the extent of Samot's communication challenges and the inadequacy of the interpretation provided at trial. The judge found that the failure to make the required determination under § 92A raised a substantial risk of a miscarriage of justice and allowed the motion for a new trial. The Commonwealth appealed.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The court held that the defendant had the right to challenge the admission of Samot's testimony due to the statutory violation. The court found that the failure to make the required determination under § 92A was an error that prejudiced the defendant, as it affected the accuracy of the interpretation and the ability to cross-examine the witness effectively. The court concluded that the judge did not abuse her discretion in granting a new trial. View "Commonwealth v. Lozada" on Justia Law

The defendant was convicted of operating a motor vehicle after his license had been revoked. The revocation was due to a prior conviction for motor vehicle homicide and operating under the influence (OUI). The defendant argued that his motion to dismiss the complaint should have been allowed because the citation was not issued at the time and place of the violation, as required by the "no-fix" statute. The police learned of the violation weeks later through a television news report and issued the citation after investigating the report.In the Dedham Division of the District Court Department, the defendant's motion to dismiss was denied. The judge found that additional time was reasonably necessary to investigate the violation. The defendant's motion for reconsideration was also denied. At trial, the judge found the defendant guilty and sentenced him to eighteen months in a house of correction. The defendant appealed, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts affirmed the lower court's decision. The court held that the delay in issuing the citation was justified because additional time was reasonably necessary to investigate the violation. The court also found that the evidence was sufficient to prove that the defendant operated a motor vehicle after his license had been revoked and before it was restored. The court rejected the defendant's argument that the penalty only applied during the pendency of the revocation period, clarifying that the penalty continues to apply until the license or right to operate is restored. The judgment was affirmed. View "Commonwealth v. Foley" on Justia Law

The defendant was charged with carrying a firearm without a license, carrying a loaded firearm without a license, and possession of ammunition without a firearm identification card following a traffic stop where police found a loaded firearm in his pocket. At trial, the Commonwealth sought to prove the defendant lacked a license to carry a firearm through the testimony of a Department of Criminal Justice Information Services (DCJIS) employee. The employee testified that a search of the DCJIS-maintained Statewide database using the defendant's name and a birth date provided by the district attorney's office returned no results. However, the judge did not admit the testimony regarding the birth date as evidence of the defendant's actual birth date due to the witness's lack of personal knowledge, and the Commonwealth did not introduce other evidence establishing the defendant's birth date.The trial judge denied the defendant's motion for a required finding of not guilty and convicted him of possessing a firearm without a license and possessing ammunition without a firearm identification card. The defendant appealed, challenging the sufficiency of the Commonwealth's proof of nonlicensure and arguing that the testimony violated his right to confront witnesses under the Sixth Amendment and the Massachusetts Declaration of Rights.The Supreme Judicial Court of Massachusetts reviewed the case and held that a witness testifying about a search of a public records database must be familiar with the process of searching the database and the government record-keeping practices. The court found no abuse of discretion in admitting the DCJIS employee's testimony. However, the court concluded that the Commonwealth's proof of lack of licensure was insufficient because it did not introduce evidence that the birth date used to search the database was the defendant's actual birth date. Consequently, the court reversed the defendant's convictions and remanded for entry of judgments in favor of the defendant. View "Commonwealth v. Smith" on Justia Law

In January 2018, Shaquille Browder was shot and killed in a parking lot in Boston. Ralph Brown was indicted and convicted of first-degree murder based on deliberate premeditation. Brown appealed, claiming errors by judges and the prosecutor, and insufficient evidence of his guilt.The Superior Court denied Brown's pretrial motions to suppress evidence obtained from search warrants for a vehicle's infotainment system and his cell phone's location data. The court found no material misstatements or intent to deceive in the affidavits supporting the warrants. Brown's motion to dismiss the indictments, alleging grand jury impairment due to improper statements by a detective, was also denied. The court ruled that the statements did not influence the grand jury's decision to indict.The Massachusetts Supreme Judicial Court reviewed the case and upheld Brown's conviction. The court found that the evidence, including surveillance footage, cell phone records, and vehicle rental information, was sufficient to support the jury's verdict. The court also addressed Brown's claims of improper jury empanelment and prosecutorial misconduct during closing arguments. It concluded that any errors in voir dire questions about motive did not result in a substantial likelihood of a miscarriage of justice. The court determined that the prosecutor's comments during closing arguments were permissible and did not shift the burden of proof or misstate facts.The court affirmed Brown's conviction of first-degree murder but vacated his convictions for carrying a firearm without a license and carrying a loaded firearm, remanding for further proceedings consistent with recent case law. View "Commonwealth v. Brown" on Justia Law

In the early morning of August 10, 2014, the defendant entered an apartment in Lowell and fatally shot two occupants. He was convicted of felony-murder, armed home invasion, and possession of a firearm without a license. The defendant appealed, raising several arguments.The Superior Court jury found the defendant guilty of felony-murder, armed home invasion, and unlawful possession of a firearm. The defendant argued that the jury should have been instructed that the Commonwealth needed to prove the absence of mitigating circumstances for felony-murder, that the prosecutor improperly appealed to emotion, that the judge prejudged the sentences, and that defense counsel was ineffective for not presenting mitigating information at sentencing. The defendant also contended that his convictions for armed home invasion and firearm possession should be vacated.The Supreme Judicial Court of Massachusetts reviewed the case. The court vacated the armed home invasion conviction as duplicative of the felony-murder conviction and vacated the firearm possession conviction due to improper jury instructions regarding the burden of proof for licensure. The court remanded the firearm charge for further proceedings. The court affirmed the felony-murder convictions, finding no error in the jury instructions regarding mitigating circumstances, no improper appeals to emotion by the prosecutor, and no substantial likelihood of a miscarriage of justice due to the judge's sentencing comments or defense counsel's performance. The court also declined to exercise its authority to reduce the verdicts under G. L. c. 278, § 33E. View "Commonwealth v. Poum" on Justia Law

Three juveniles, Frederick F., Angela A., and Manolo M., were adjudicated delinquent on charges of resisting arrest. The events occurred on October 3, 2019, near Brockton High School, where a large crowd of students had gathered, leading to multiple altercations. Frederick yelled profanities at police officers and refused to leave the area, Angela recorded officers with her cell phone while yelling at them, and Manolo attempted to punch an officer and engaged in a physical struggle.The Juvenile Court denied Frederick's motion to dismiss the complaint for lack of probable cause and denied all three juveniles' motions for required findings of not delinquent. The Appeals Court affirmed the adjudications for resisting arrest but vacated Manolo's adjudication for assault and battery on a police officer due to an error in jury instructions.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the evidence was sufficient to support the adjudications for resisting arrest. For Frederick, the court found that the circumstances provided a basis for a good-faith judgment to arrest him for disorderly conduct. For Angela, the court concluded that her conduct of thrusting her cell phone within inches of officers' faces and resisting arrest by pulling away constituted the use of physical force. For Manolo, the court determined that his physical struggle with officers on the ground, following his aggressive actions, provided sufficient evidence of using physical force to resist arrest.The court affirmed the adjudications of delinquency for resisting arrest for all three juveniles and remanded for further proceedings on Manolo's vacated adjudication for assault and battery on a police officer. View "Commonwealth v. Manolo M." on Justia Law