Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions for two counts of murder in the first degree and the denial of his motion for a new trial, holding that Defendant was not deprived of his constitutional right to the effective assistance of counsel.On appeal, Defendant argued, among other things, that it was manifestly unreasonable for his trial counsel to forgo mental health defenses in favor of a third-party culprit defense. The Supreme Judicial Court disagreed, holding (1) trial counsel was not ineffective for urging one defense over the other, and Defendant was not prejudiced by his trial counsel's performance; and (2) there was no basis upon which to exercise the Court's extraordinary authority to order a new trial or to reduce the verdicts pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Velez" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief.Petitioner was charged in six separate complaints with several offenses, including assault and battery on a family or household member. The Commonwealth moved to join the cases, and a district court judge allowed the motion. After Petitioner's motion for reconsideration was denied he filed this petition, arguing that not reviewing the joinder decision now could lead to irreversible consequences. A 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 "Morris v. Commonwealth" on Justia Law

In this personal injury suit, the Supreme Judicial Court affirmed the judgment of the trial judge allowing Defendants' motion for a mistrial after Plaintiff's counsel purportedly made improper comments during his closing argument, holding that the judge did not abuse her discretion in allowing the motion for a mistrial.The judge in this case chose to reserve decision on Defendants' motion for a mistrial until after the jury rendered their verdict. Only after the jury found for Plaintiff did the judge allow the motion and declare a mistrial. After a second trial, Plaintiff once again prevailed but was awarded significantly lower damages. On appeal, Plaintiff argued that once the verdict had been returned, the motion for a mistrial should have been evaluated under the standard for a motion for a new trial. The Supreme Judicial Court affirmed, holding (1) in civil cases, a motion for a mistrial must be decided when made, and after a jury verdict the appropriate method to seek to have a case tried again is by filing a motion for a new trial; and (2) because this requirement applies only prospectively, the judge in this case properly allowed the motion for a mistrial. View "Fitzpatrick v. Wendy's Old Fashioned Hamburgers of New York, Inc." on Justia Law

The Supreme Judicial Court affirmed the decision of the Appellate Tax Board granting certain vendors' applications for refunds through the general abatement process for the portion of sales tax they had paid to the Commonwealth that was attributable to out-of-state use of software, holding that Mass. Gen. Laws ch. 64H, 1 creates a statutory right to apportionment for software transferred for use in multiple states.The vendors in this case sold or licensed software to Hologic, Inc., a medical device company headquartered in Massachusetts. At the time sales taxes were due, the vendors remitted tax payments to the Commonwealth based on the entire value of the transactions. When the vendors were informed that only a portion of the software was to be used in the Commonwealth, they applied for refunds. The Commissioner of Revenue denied the applications for abatement on the grounds that the regulations for apportionment were not followed. The Board granted the requested abatements. The Supreme Judicial Court affirmed, holding (1) the vendors had a statutory right to apportionment; and (2) the general abatement process was available to the vendors, despite their having paid sales tax in excess of that properly apportioned to sales in the Commonwealth. View "Oracle USA, Inc. v. Commissioner of Revenue" on Justia Law

The Supreme Judicial Court dismissed as moot Plaintiffs' appeal arguing that the Department of Correction (DOC) illegally kept them in custody after a final decision on their petitions for medical parole had been made by the Commissioner of Correction but answered two questions reported by the single justice.Plaintiffs were two prisoners recently released under the medical parole statute. Before their actual release from incarceration, Plaintiffs sought relief from a single justice of the court. The single justice denied Plaintiffs' request for relief and separately reported two questions to the Supreme Judicial Court regarding the requirements of finding a replacement for a prisoner who is granted medical parole and the timing of a prisoner's release after medical parole is granted. The Supreme Judicial Court dismissed Plaintiffs' appeal as moot and answered (1) after medical parole is granted the DOC must develop comprehensive plans including a proposed course and site for treatment; and (2) once a favorable decision by the Commissioner allows release on medical parole, the DOC must be proactive in working to release the prisoner expeditiously. View "Malloy v. Department of Correction" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the court affirming the decision of the Board of Registration in Medicine revoking Joseph Knight's inchoate right to renew his medical license, holding that the Board's decision was amply supported by the evidence and that Knight failed to demonstrate prejudice from any alleged legal or procedural defect.During his career as a physician, Knight was licensed to practice medicine in multiple jurisdictions in the United States. After receiving complaints about his prescription practices, Knight applied for a second renewal of his Massachusetts license. On his application, Knight admitted that he had been the subject of a disciplinary action but denied other allegations. The Board then issued a statement of allegations against Knight, and the disciplinary proceedings proceeded. The Supreme Judicial Court affirmed, holding that there was no doubt that the Board was justified in reach the result it did. View "Knight v. Board of Registration in Medicine" on Justia Law

The Supreme Judicial Court answered three reported questions regarding judicial proceedings stemming from the denial of a petition for medical parole.Plaintiffs - Raymon Harmon and Brian Racine - were prisoners who applied for release under Mass. Gen. Laws ch. 127, 119A, the medical parole statute. The Commissioner of Correction denied both petitions. Harmon sought judicial review but died while his case was pending in the superior court. Racine requested that the Commissioner reconsider her decision and died after the Commissioner denied the request. The Supreme Judicial Court held (1) a prisoner's death renders judicial proceedings stemming from the denial of a petition for medical parole moot, but a court may use its discretion to decide the case; (2) the regulations of the Department of Corrections that limit the ability of prisoners to submit subsequent petitions for medical parole after one has been denied or not acted upon are void; and (3) section 119A applies only to committed offenders serving a sentence and not to pretrial detainees. View "Harmon v. Commissioner of Correction" on Justia Law

The Supreme Judicial Court reversed Defendant's convictions of armed assault with intent to murder and related charges, holding that the trial judge erred in admitting evidence obtained from a global positioning system (GPS) device that Defendant was wearing at the time of the crime.Due to his probation on a federal drug charge, Defendant was wearing a GPS ankle monitor on the night of the shooting at issue. During trial, the court admitted data from Defendant's GPS device showing his location at the time of the shooting and that his speed matched the shooter's movements. The Supreme Judicial Court reversed Defendant's convictions, holding that because the GPS device Defendant was wearing had never been formally tested for its ability to measure speed, the trial judge abused his discretion in admitting the speed evidence. View "Commonwealth v. Davis" 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 reversible error either in any issue raised by Defendant or in this Court's review under Mass. Gen. Laws ch. 33E.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress handwritten note and oral statements he made to officers while he was hospitalized; (2) Defendant was not entitled to reversal of his convictions on the grounds of error in the trial judge's evidentiary rulings; (3) the trial judge did not err in denying Defendant's motion for a new trial; and (4) there was no basis for reducing Defendant's sentence on the murder conviction or ordering a new trial. View "Commonwealth v. Welch" on Justia Law

The Supreme Judicial Court affirmed the judgment of a judge of the superior court dismissing Relator's claims alleging that Defendants collectively engaged in and conspired to engage in fraud, holding that this suit was subject to the public disclosure bar of the Massachusetts False Claims Act (MFCA), Mass. Gen. Laws ch. 12, 5A-50.The MCFA contains a public disclosure bar that generally requires that an action be dismissed if substantially the same allegations or transactions as alleged have previously been disclosed through certain enumerated sources. Relator commenced this action on behalf of the Commonwealth against certain financial institutions and their subsidiaries. Defendants argued that dismissal was required pursuant to the MFCA's public disclosure bar because the subject transactions had previously been disclosed to the public through news media and Relator was not an original source of the information concerning the fraud. The superior court dismissed the complaint. The Supreme Judicial Court affirmed, holding that the superior court correctly dismissed Relator's claims. View "Rosenberg v. JPMorgan Chase & Co." on Justia Law