Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court held that social workers, and their approving supervisors, in the Department of Children and Families who attest to facts in sworn affidavits as part of care and protection proceedings commenced by the Department in the juvenile court pursuant to Mass. Gen. Laws. ch. 119, 24 are entitled to absolute immunity in these circumstances.Plaintiff brought an action pursuant to 42 U.S.C. 1983 against a social worker with the Department, alleging that the social worker intentionally misrepresented facts in a sworn affidavit filed in support of a care and protection petition in the juvenile court. Plaintiff further alleged that the social worker's area supervisor (together, with the social worker, Defendants) was liable because she had approved the social worker's actions. Defendants filed a motion for judgment on the pleadings, arguing that they were entitled to absolute immunity. A superior court judge allowed the motion. The Supreme Judicial Court affirmed, holding that Defendants were entitled to absolute immunity under the circumstances of this case. View "C.M. v. Commissioner of Department of Children & Families" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of unlawful distribution of heroin as a subsequent offender and unlawful possession of heroin with intent to distribute as a subsequent offender, holding that the superior court did not err by denying Defendant's motion to suppress and that there was no other error.In his suppression motion, Defendant sought to suppress evidence found during a warrantless search of a motor vehicle. The superior court denied the motion to suppress. The Supreme Judicial Court affirmed the denial of the suppression motion and Defendant's convictions, holding (1) the police had probable cause to search the vehicle, and there was no error in the denial of the motion to suppress; (2) the trial judge erred in allowing the admission of an in-court identification made by a police officer, but the error did not prejudice Defendant; and (3) there was no substantial risk of a miscarriage of justice as to the jury instructions on possession and distribution of narcotics. View "Commonwealth v. Ortiz" on Justia Law

The Supreme Judicial Court affirmed the judgment of the sentencing judge denying Defendant's motion to dismiss revocation proceedings and the finding that Defendant violated conditions of his probation, holding that there was no error.Defendant was convicted of indecent assault and battery on a child and sentenced to two separate periods of incarceration, the latter of which was to be suspended in favor of probation. Upon release from his confinement, Defendant began serving the probation phase of his sentence. One year later, Defendant was found to have violated the conditions of his probation, and his probation was revoked. On appeal, Defendant argued that his probationary term should have terminated prior to the occurrence of the violations. The Supreme Judicial Court affirmed, holding that it was not fundamentally unfair to delay the commencement of Defendant's probationary term until he was released from the treatment center into the community. View "Commonwealth v. Medina" on Justia Law

In this appeal from various orders regarding Defendant's pretrial detention status the Supreme Judicial Court vacated the decision of the single justice concluding that no due process violation occurred regarding one case and ruled that the other case was moot, holding that remand was required for a determination as to whether Defendant's continued pretrial confinement violates due process.Defendant had been held in pretrial detention for more than eighteen months on charges arising out of the Chelsea Division and the Lynn Division of the District Court Department. At the time of this opinion, Defendant had been held for over a year beyond his initial trial dates. Defendant was eventually acquitted of the charges in the Chelsea case. In the Lynn case, Defendant's trial was delayed due to the COVID-19 pandemic. At issue was whether the prolonged detention violated Defendant's due process rights. The Supreme Judicial Court held (1) in analyzing whether a defendant's pretrial detention violates due process this opinion contains a procedural framework; (2) because Defendant was acquitted in the Chelsea case, that case was moot; and (3) as to the Lynn case, the matter must be remanded for further proceedings. View "Mushwaalakbar v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the order of the superior court judge granting Defendant's motion to dismiss this wrongful death action, holding that Plaintiff failed to demonstrate that the duty Defendant owed to the decedent in this case extended to protecting him from injury caused by a third party.Plaintiff was the mother of Keivan Heath, who was shot and killed at a house party by an unidentified shooter. Plaintiff, as the personal representative of the decedent's estate, sued Defendant, the property owner who had rented the house for the party, for wrongful death. The superior court dismissed the action. The Supreme Judicial Court affirmed, holding that the complaint did not plausibly suggest either that Defendant owed a legal duty to the decedent by virtue of his property ownership or that Defendant voluntarily assumed such a duty. View "Heath-Latson v. Styller" on Justia Law

The Supreme Judicial Court affirmed the Land Court's judgment affirming the decision of the Zoning Board of Appeals of the town of Lynnfield upholding the decision of the building inspector ordering Plaintiff to cease and desist offering his family home for short-term rentals, holding that there was no error.On appeal, Plaintiff argued that the use of his home for short-term rentals constituted a prior nonconforming use that was exempt from the town's zoning bylaw that, as amended, expressly forbade short-term rentals in single-residence zoning districts. The Supreme Judicial Court disagreed, holding that Plaintiff's use of the property for short-term rentals was not a permissible use under the town's zoning bylaw as it existed prior to its amendment. View "Styller v. Zoning Board of Appeals of Lynnfield" on Justia Law

The Supreme Judicial Court vacated the judgment of the superior court affirming the decision of the Sex Offender Registry Board denying Doe's motion to vacate her final classification as a level three sex offender, holding that Doe's premature classification violated due process.In 2012, years before her potential release date from prison, Doe was classified as a level three sex offender. She did not challenge the classification at the time. In 2019, Doe moved to vacate the final classification on the grounds that it was premature. The Board denied the motion. The Supreme Judicial Court affirmed, holding that the classification violated due process because it served little to no purpose, posed an unnecessary risk of harm and error and was not justified by the Board's limited interest in finality or administrative efficiency. View "Doe v. Sex Offender Registry Board" on Justia Law

The Supreme Judicial Court vacated the decision of the superior court judge allowing Defendant's motion to suppress, holding that Defendant enjoyed no reasonable expectation of privacy in the text messages sent by him that were stored on a cellular telephone belonging to, and possessed by, another person.Defendant and six codefendants were indicted on charges of trafficking in cocaine, conspiracy to violate drug laws, and conspiracy to commit money laundering. The charges stemmed from an investigation originating, in part, from evidence acquired during a search of a codefendant's cell phone. The owner of the telephone filed a motion to suppress evidence obtained as a result of the search of his phone, including the contents of text messages sent by Defendant. Defendant moved to join the motion. The Commonwealth opposed the motion, arguing that Defendant lacked standing to challenge the search. The judge ruled that Defendant had standing and allowed him to join the motion. The Supreme Judicial Court reversed, holding that Defendant could not challenge the reasonableness of the search because he lacked a reasonable expectation of privacy in the sent text messages. View "Commonwealth v. Delgado-Rivera" on Justia Law

The Supreme Judicial Court affirmed in part the judgment of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3 seeking bail review but remanded the case for the judge to make required findings pursuant to Brangan v. Commonwealth, 477 Mass. 691 (2017), holding that further proceedings were necessary.Petitioner was indicted on numerous charges. A superior court judge initially set cash bail at $100,000. Two years later, Petitioner, who was unable to pay the cash bail, sought review of the bail determination. A judge reduced the cash bail to $30,000 but did so without any findings or explanation. Petitioner later filed this petition seeking bail review, arguing that the cash bail amount of $30,000 was excessive. The single justice denied the petition without a hearing. The Supreme Judicial Court remanded the case with directions for the judge who made the bail reduction decision to make the required findings for that decision pursuant to Brangan, holding that the judge should have made findings for that decision. View "Boisvert v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner, an inmate, filed a complaint seeking declaratory and injunctive relief in connection with two Massachusetts Department of Correction (DOC) standard operating procedures (SOPs) implemented earlier that year. Petitioner also sought a temporary restraining order and a preliminary injunction to prevent DOC from enforcing the SOPs during the pendency of this case. The superior court judge denied Petitioner's injunction request as moot and ordered that judgment enter declaring that implementation of the first SOP violates 103 Code Mass. Regs. 481. Petitioner then filed this petition seeking review of the superior court's judgment and orders. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that Petitioner failed to show that review of the trial court decision could not adequately be obtained on appeal or by other available means. View "Wright v. Department of Correction" on Justia Law