Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court reversed the order of the motion judge granting a continuance sought by the Commonwealth for the express purpose of delaying resolution of the case past the juvenile's eighteenth birthday, holding that, absent certain findings, it was an abuse discretion to allow the continuance.Where the motion judge granted the continuance in this case, it meant the difference between twenty days and twelve months the juvenile spent in the custody of the Department of Youth Services. The Supreme Court reversed, holding (1) continuances for the sole purpose of extending the time of commitment are authorized only if there is clear and convincing evidence that the continued commitment is necessary for the rehabilitation of the juvenile and express findings are made to that effect after an evidentiary hearing; and (2) because no such findings were made in the instant case and the juvenile had already turned eighteen, it was an abuse of discretion to allow the continuance. View "Noah v. Commonwealth" on Justia Law

The Supreme Judicial Court reversed the order of the trial judge denying Barbara Howard's motion to dismiss a petition seeking to partition two adjacent parcels of land in Foster that Howard Dunn and Howard owned as joint tenants with a right of survivorship, holding that Howard's motion to dismiss should have been granted.During the partition proceedings, Dunn died. Howard subsequently filed her motion to dismiss for lack of subject matter jurisdiction, asserting that Dunn's death vested full title in her as the surviving joint tenant. The trial judge denied the motion. The Supreme Judicial Court reversed, holding (1) the partition proceedings and the acceptance of a buyer's offer to purchase the property did not sever the joint tenancy or terminate Howard's right of survivorship; (2) Mass. Gen. Laws ch. 241, 26 does not confer standing on the heirs of a joint tenant to continue a partition action; and (3) where a party lacks standing under Mass. Gen. Laws ch. 241, 1, Mass. Gen. Laws ch. 241, 25 does not permit the land court to retain jurisdiction over the defective suit. View "Battle v. Howard" on Justia Law

The Supreme Judicial Court held that the proper measure of damages for the private right of action for Wage Act violations under Mass. Gen. Laws ch. 149, 150 when the employer pays wages after the deadlines provided in the aCt but before the employee files a complaint is treble the amount of the late wages, not trebled interest.When Plaintiff was discharged from her employment with the City of Methuen the City owed her almost $9000 for accrued vacation time. While the Act required the City to pay this amount to Plaintiff on the day of her termination the City did not pay her until three weeks later. One year later, the City paid Plaintiff an amount representing the trebled interest for the three weeks between Plaintiff's termination and the payment of Plaintiff's vacation pay. Plaintiff subsequently brought this lawsuit. The superior court judge concluded that Plaintiff was only entitled to treble interest for the three-week delay in receiving her vacation pay. The Supreme Judicial Court remanded the case, holding that late-paid wages are "lost wages" for purposes of the Wage Act. View "Reuter v. City of Methuen" on Justia Law

The Supreme Judicial Court held that "tower dumps" are not per se unconstitutional and that investigators may use tower dumps so long as they comply with the warrant requirements of article 14 of the Massachusetts Declaration of Rights.The Commonwealth obtained search warrants for seven different "tower dumps," a law enforcement tool that provides investigators with the cell site location information for all devices that connected to specific cell towers during a particular time frame, corresponding to the locations of several crimes. Defendant was ultimately charged with six robberies and a homicide. Defendant moved to suppress all evidence obtained from the tower dumps as the fruit of an unconstitutional search. The superior court judge denied the motion. The Supreme Judicial Court reversed in part, holding (1) investigators may use tower dumps so long as they comply with the warrant requirements of article 14; (2) the second of the two warrants in this case was supported by probable cause and therefore did not offend the Massachusetts Declaration of Rights; but (3) the first warrant was not supported by probable cause, and any evidence obtained from it must be suppressed. View "Commonwealth v. Perry" on Justia Law

The Supreme Judicial Court vacated the order of the superior court judge allowing the forfeiture in this case, holding that firearms found to be improperly secured according to the requirements of Mass. Gen. Laws ch. 140, 131L are not subject to forfeiture under Mass. Gen. Laws ch. 276, 3(b), which regulates the disposal of certain firearms seized during the execution of a search warrant.Police obtained a search warrant to search Defendant's home for a firearm allegedly used in an altercation. During the search, officers found that some of Defendant's more than 240 firearms appeared to be improperly secured. Defendant was subsequently indicted on twenty-seven counts of improperly securing a firearm and convicted on twelve counts. Defendant later moved for the return of all twenty-seven of the seized firearms. A superior court judge ordered the return of the firearms seized during during the execution of the search warrant with the exception of the twelve that had been found to have been improperly secured, which the judge ordered be forfeited and destroyed. The Court of Appeals vacated the order below, holding that Mass. Gen. Laws ch. 140, 129D applies only to firearms "deliver[ed] or surrender[ed]," not to those seized during a lawful search. View "Commonwealth v. Fleury" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in the first degree and home invasion, holding that Defendant was not entitled to relief on his claims of error.On appeal from his conviction and the denial of his motion for a new trial Defendant asserted a number of allegedly erroneous evidentiary rulings, claimed that the Commonwealth failed to comply with its discovery obligations, and contended that the verdict was against the weight of the evidence. The Supreme Court affirmed, holding (1) there was no reversible error or abuse of discretion in the proceedings below; and (2) there was no reason for this Court to exercise its authority to grant relief pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Kostka" on Justia Law

The Supreme Judicial Court answered two questions of law concerning the authority of counsel or the courts to protect the interests of putative class members when the named plaintiff has died, no party has been substituted for the named plaintiff and no motion has been made to certify the putative class.Charles Kingara brought this lawsuit alleging both class and individual causes of action arising under the wage act, the minimum fair wage law, and the overtime law. Before Kingara's counsel had filed for class certification Kingara died. Thereafter, Plaintiff's counsel filed a motion to order notice to putative class members informing them of Kingara's death and inviting them to join the action. After the motion was granted, Defendants filed a petition for interlocutory relief, which resulted in the questions of law before this Court. The Supreme Judicial Court held that, under the circumstances, counsel had no authority to act on behalf of Kingara or the putative class, but the courts may act to protect the interests of the putative class members when those individuals would face significant prejudice without notice. View "Kingara v. Secure Home Health Care Inc." on Justia Law

The Supreme Judicial Court reversed in part the denial of Defendant's motions for postconviction relief and otherwise affirmed Defendant's conviction of murder in the first degree based on both deliberate premeditation and extreme atrocity or cruelty and two counts of assault and battery by means of a dangerous weapon, holding that the trial court erred in part.Here, Defendant appealed from his convictions and from the denial of two postconviction motions. One of those motions requested forensic testing pursuant to Mass. Gen. Laws ch. 278A and the other requesting an advance of expert fees. The Supreme Judicial Court reversed in part, holding (1) as to Defendant's direct appeal there was no reversible error; (2) there was no reason to grant relief under Mass. Gen. Laws ch. 278, 33E; (3) the trial court properly denied Defendant's motion for expert fees because it was premature; but (4) Defendant's motion requesting forensic analysis met the threshold requirements of Mass. Gen. Laws ch. 278A, 3, and therefore, the trial court erred in dismissing the motion. View "Commonwealth v. Steadman" on Justia Law

The Supreme Judicial Court held that, where a franchisee is an "individual performing any service" for a franchisor, the three-prong test set forth in the independent contractor statute, Mass. Gen. Laws ch. 149, 148B, applies to the relationship between a franchisor and the individual and is not in conflict with the franchisor's disclosure obligations under the "FTC Franchise Rule."Plaintiffs filed a complaint alleging that they were 7-Eleven employees and had been misclassified as independent contractors in violation of the independent contractor statute, Mass. Gen. Laws ch. 149, 148B. A federal judge granted summary judgment in favor of Eleven, concluding that the independent contractor statue does not apply to franchisee-franchisor relationships because there is a conflict because that statute and the FTC franchise Rule, 16 C.F.R. 436.1 et seq., a series of regulations promulgated by the Federal Trade Commission (FTC) regarding franchises. The Supreme Judicial Court answered a certified question, holding that the independent contractor statute applies to the franchisor-franchisee relationship and is not in conflict with the franchisor's disclosure obligations set forth in the FTC Franchise Rule. View "Patel v. 7-Eleven, Inc." on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of carrying a firearm without a license, holding that the trial court erred in denying Defendant's motion to suppress.At issue was whether police officers may conduct a traffic stop on the basis of a traffic violation after having resolved the violation at a prior encounter, then having allowed the vehicle to leave, without any other traffic violation taking place. Defendant challenged the constitutionality of the traffic stop in this case under article 14 of the Massachusetts Declaration of Rights. The Supreme Judicial Court reversed the judgment of the trial court denying Defendant's motion to suppress and vacated his conviction, holding (1) police may not conduct a traffic stop on the basis of a traffic violation after having previously addressed the violation and having resolved the issue in a separate, discrete encounter; and (2) in the instant case, police lacked the authority to conduct the second traffic stop, and therefore, the stop was unreasonable under article 14. View "Commonwealth v. Daveiga" on Justia Law