Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree and vacated his conviction of accessory after the fact to murder, holding that, under the circumstances, Defendant could not convicted of joint venture murder in the first degree and of accessory after the fact.Specifically, the Supreme Judicial Court held (1) there was sufficient evidence to prove murder in the first degree; (2) the jury instruction on joint venture liability was a correct statement of the law; (3) while the evidence was sufficient to convict Defendant as an accessory after the fact, because one cannot properly be convicted of a crime and of being an accessory after the fact to the same crime, this conviction must be vacated; (4) the trial judge did not abuse her discretion by failing to order the trial severed; (5) reversible error did not result from the judge's response to a jury question; and (6) there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Watson" on Justia Law

In this case involving the Attorney General's investigation into Facebook, Inc. under Mass. Gen. Laws ch. 93A focusing on whether Facebook misrepresented the extent to which it protected or misused user data the Supreme Judicial Court held that most of the civil investigative demands (demands) served by the Attorney General were not covered by the attorney-client privilege but that the work product doctrine applied to the documents requested.After potential widespread misuse of Facebook user data by third-party applications was reported Facebook started an investigation, known as the app developer investigation (ADI), to identify the extent to which the apps had misused user data and to determine potential resulting legal liabilities. At issue were six requests contained with the Attorney General's demands. Facebook argued that the attorney-client privilege and the work product doctrine protected the information. A judge determined that most of the information was neither privileged nor work product. The Supreme Judicial Court reversed in part, holding (1) the documents sought by the first five requests were covered by the work product doctrine; (2) the sixth request required further review; and (3) a remand was required to determined whether some of the documents requested constituted opinion work product. View "Attorney General v. Facebook, Inc." on Justia Law

The Supreme Judicial Court remanded this matter to the county court for entry of a judgment allowing Defendant's petition pursuant to Mass. Gen. Laws ch. 211, 3 and ordering that the superior court judge's order hospitalizing Defendant under Mass. Gen. Laws ch. 123, 16(a) be vacated, holding that Defendant's substantive due process rights were violated.A grand jury returned a twelve-count indictment charging Defendant with two counts of armed carjacking and multiple related charges. After a jury-waived trial, Defendant was found not criminally responsible by reason of mental illness. Thereafter, the judge granted the Commonwealth's motion to hospitalize Defendant for evaluation pursuant to section 16(a) for forty days. Defendant filed a petition pursuant to section 3 requesting relief from confinement. A single justice denied the petition. The Supreme Judicial Court remanded the matter, holding that there was no constitutionally adequate justification to temporarily commit Defendant under section 16(a). View "Garcia v. Commonwealth" on Justia Law

The Supreme Judicial Court exercised its authority under Mass. Gen. Laws ch. 278, 33E to reduce the jury's verdict of murder in the first degree to murder in the second degree, holding that, in light of the circumstances, a verdict of murder in the second degree was more consonant with justice.Defendant was fifteen years old when he killed the victim and had a history of trauma, impaired cognitive abilities, and mental health issues. Defendant was convicted of murder in the first degree and sentenced to life with the possibility of parole after twenty years. On appeal, the Supreme Judicial Court rejected most of Defendant's arguments but agreed that, in the circumstances of this case, there was ground for reducing the verdict from first to second degree murder. View "Commonwealth v. Concepcion" on Justia Law

The Supreme Judicial Court affirmed in part and vacated in part the judgment of the superior court granting summary judgment to Defendants on some of Plaintiffs' claims and granting judgment for Plaintiffs on their implied warranty of habitability and Mass. Gen. Laws ch. 93A claims, holding that Defendants' motion for directed verdict or motion for judgment notwithstanding the verdict should have been allowed on the chapter 93A and warranty of habitability claims.After Plaintiffs purchased a piece of real property from Defendants they discovered various defects in the property. They brought this action against Defendants. The superior court granted summary judgment for Defendants on Plaintiffs' fraud and misrepresentation and defective and deficient renovation work claims. After a trial, the jury found in favor of Plaintiffs on the warranty of habitability and chapter 93A claims. The Supreme Judicial Court vacated the judgment in part, holding that Defendants' motions for a directed verdict or judgment notwithstanding the verdict should have been allowed on the chapter 93A and warranty of habitability claims. View "Sullivan v. Five Acres Realty Trust" on Justia Law

The Supreme Judicial Court held that should Littleton, Acton, or both towns choose to exercise their rights to take the waters of Nagog Pond and apply for a permit under the Water Management Act (WMA), Mass. Gen. Laws ch. 21G, a special act passed by the Legislature in 1884 - St. 1884, c. 201 (1884 act) - the WMA will not provide the towns with a priority right over Concord's registration.The 1884 act granted Concord the right to use Nagog Pond, located in Littleton and Acton, as a public water supply. The act, however, provided that Littleton, Acton, or both could take the pond waters and that their water needs "shall be first supplied." Because Concord had exercised its rights under the 1884 act but Littleton and Acton had not exercised their rights, at issue was whether those rights still existed after the passage of the WMA. The Supreme Court held (1) the WMA impliedly repealed the provision in the 1884 act that provided that the needs of the residents of Littleton and Acton "shall be first supplied"; but (2) the WMA did not impliedly repeal the provisions of the 1884 act that granted Concord the right to "take and hold" the Nagog Pond waters. View "Concord v. Water Department of Littleton" 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 seeking an order keeping her approved federal rental voucher under the Massachusetts rental voucher program in active status, holding that, under the circumstances, the single justice was within his authority in declining to grant relief.In her petition, Petitioner contested an order transferring her case against the United States Department of Housing and Urban Development to the Housing Court and then appealed that order. Petitioner also sought to restore her federal housing benefits pending her appeal. After the superior court denied relief Petitioner filed this petition seeking the same relief. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice did not err in denying relief. View "Linardon v. Boston Housing Authority" on Justia Law

The Supreme Judicial Court affirmed the two judgments of a single justice of the court denying Petitioner's petitions for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3, by which Petitioner sought pretrial release or a reduction in bail, holding that the single justice properly denied relief.Petitioner was charged with rape and indecent assault and battery on a person age fourteen or older. Bail was set at $75,000, an amount Petitioner was unable to post bail in this amount. Petitioner moved for immediate release based on the dangers of the coronavirus pandemic. The superior court denied relief. Upon further bail hearing, the judge reduced Petitioner's bail to $25,000. Petitioner was unable to post bail in this amount. Petitioner petitioned a single justice for relief from the two orders, but the justice denied relief. The Supreme Judicial Court affirmed, holding that the single justice did not err or abuse her discretion in denying relief. View "Oquendo v. Commonwealth" on Justia Law

The Supreme Judicial Court held that the ministerial exception did not apply to Plaintiff, an associate professor of social work at a private Christian liberal arts college, and therefore, the superior court judge did not err in dismissing on summary judgment Gordon College's affirmative defense of the ministerial exception in this retaliation complaint.The ministerial exception prohibits government interference with employment relationships between religious institutions and their ministerial employees. Plaintiff, a tenured associate professor of social work at Gordon, alleged that Defendants - Gordon and its president and provost (collectively, Gordon) - unlawfully retaliated against her for her opposition to Gordon's policies and practices regarding LGBTQ+ individuals. The parties cross-moved for summary judgment on the question of whether the ministerial exception barred Plaintiff's claims. The superior court allowed Plaintiff's motion but denied Gordon's, concluding that Gordon was a religious institution but that Plaintiff was not a ministerial employee. The Supreme Judicial Court affirmed, holding that the superior court judge did not err in dismissing the affirmative defense of the ministerial exception. View "DeWeese-Boyd v. Gordon College" on Justia Law

The Supreme Judicial Court affirmed the underlying judgment of the Housing Court in this summary process eviction action awarding possession to Landlord, holding that Tenant's appeals regarding his requests for disabilities accommodations in the Appeals Court and in the single justice session were moot.After a bench trial the Housing Court judge awarded possession to Landlord but granted Tenant a reasonable accommodation in the form of a limited stay of execution. On appeal, Tenant requested disabilities accommodations from the Appeals Court, some of which were granted. Tenant also filed a petition in the county court pursuant to Mass. Gen. Laws ch. 211, 3, which a single justice denied. The appeals were consolidated. The Supreme Judicial Court affirmed, holding that Tenant's claims arising from the denial of requested disabilities accommodations in the Appeals Court and in the single justice session of this Court were moot. View "Saipe v. Sullivan & Co., Inc." on Justia Law