Justia Massachusetts Supreme Court Opinion Summaries

The case involves five plaintiffs who own and operate 7-Eleven convenience stores in Massachusetts. They entered into franchise agreements with 7-Eleven, Inc., which provided them with a license to use the 7-Eleven brand and associated business format. In return, the franchisees agreed to operate their stores according to 7-Eleven's standards and pay a franchise fee, which is a percentage of the store's gross profits. The plaintiffs claim they were misclassified as independent contractors rather than employees under Massachusetts law.The United States Court of Appeals for the First Circuit previously reviewed the case and certified a question to the Massachusetts Supreme Judicial Court (SJC) regarding whether the three-prong test for independent contractor status applies to franchise relationships. The SJC concluded that the test does apply but requires a case-specific examination of whether the individual performs any service for the alleged employer. The First Circuit then certified a second question to the SJC, asking whether the plaintiffs perform any service for 7-Eleven under the Massachusetts independent contractor statute, given their contractual obligations and the franchise fee structure.The Massachusetts Supreme Judicial Court held that the plaintiffs do not perform any service for 7-Eleven within the meaning of the independent contractor statute. The court reasoned that the franchisees operate their stores independently and chose to use the 7-Eleven brand for its market benefits. The court emphasized that the franchisees' compliance with 7-Eleven's standards is necessary to maintain the brand's integrity and does not indicate an employment relationship. Therefore, the court answered the certified question in the negative, concluding that the plaintiffs are not employees of 7-Eleven under the Massachusetts independent contractor statute. View "Patel v. 7-Eleven, Inc." on Justia Law

The plaintiffs, a group of professional models, alleged that the defendant, an adult entertainment nightclub, used their images in social media posts without consent to promote the club between August 2013 and November 2015. The plaintiffs filed a lawsuit in 2021 in the United States District Court for the District of Massachusetts, claiming defamation and related torts. This filing was outside the three-year statute of limitations specified by Massachusetts law. To avoid dismissal, the plaintiffs argued for the application of the "discovery rule," which would delay the start of the limitations period until they knew or reasonably should have known about the harm.The United States District Court for the District of Massachusetts noted that the application of the discovery rule to social media posts was a novel issue in Massachusetts law. The court certified a question to the Supreme Judicial Court of Massachusetts, asking under what circumstances material posted on social media platforms could be considered "inherently unknowable" for the purposes of applying the discovery rule in defamation and related tort claims.The Supreme Judicial Court of Massachusetts held that claims arising from social media posts accrue when a plaintiff knows or reasonably should know they have been harmed by the publication. The court emphasized that the vastness of social media and the variability in access and searchability require a fact-specific inquiry. The court concluded that whether the plaintiffs knew or should have known about the harm must often be determined by the finder of fact. However, if the social media material is widely distributed and readily accessible and searchable, a judge may determine as a matter of law that the discovery rule does not apply. View "Davalos v. Bay Watch, Inc." on Justia Law

In December 1974, Peter Sulfaro was shot and killed during an armed robbery at his shoe repair shop. His son, Paul Sulfaro, was the only witness. Three men, including Raymond Gaines, were convicted of the crime. Decades later, Gaines filed a motion for a new trial, citing new evidence and issues with the original trial.Gaines's convictions were affirmed by the Supreme Judicial Court of Massachusetts in 1978. He made several unsuccessful attempts for postconviction relief. In 2021, he filed his fourth motion for a new trial, which was granted by a Superior Court judge. The Commonwealth appealed this decision to the Supreme Judicial Court for the county of Suffolk.The Supreme Judicial Court of Massachusetts reviewed the case and upheld the decision to grant a new trial. The court found that new scientific research on eyewitness identification, which was not available at the time of the original trial, could have significantly impacted the jury's deliberations. Additionally, the court found that the Commonwealth failed to disclose exculpatory evidence, including a note about a leg injury Gaines sustained before the crime and the arrest of a key witness, David Bass, which could have been used to challenge his credibility. The court also noted that the Commonwealth had an ethical duty to disclose any witness recantations, regardless of their credibility or timing.The court concluded that the combination of these factors indicated that justice may not have been done in the original trial, and therefore, a new trial was warranted. The decision to grant a new trial was affirmed. View "Commonwealth v. Gaines" on Justia Law

The case involves a dispute between the Boston Teachers Union, Local 66, American Federation of Teachers, AFL-CIO (the union), and the School Committee of Boston (the committee). The union alleged that the committee failed to hire eighteen "cluster" paraprofessional substitutes as required by their collective bargaining agreement. An arbitrator sustained the union's grievance in July 2020 and ordered the committee to comply with the hiring requirement. The committee did not seek to vacate or modify the award. Nineteen months later, the union sought judicial confirmation of the arbitration award, which the committee opposed, claiming substantial compliance.In the Superior Court, the union filed a complaint to confirm the arbitration award and moved for judgment on the pleadings. The committee responded with a motion to dismiss for failure to state a claim. The Superior Court judge granted the committee's motion to dismiss and denied the union's motion, reasoning that there was no statutory right to confirmation when no dispute was alleged.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that under General Laws c. 150C, § 10, the Superior Court is required to confirm an arbitration award upon application by a party unless a timely motion to vacate or modify the award has been made. The court emphasized that the statute's language is clear and mandatory, stating that the Superior Court "shall" confirm the award if no such motion is pending. The court rejected the committee's argument that confirmation should be discretionary and noted that the purpose of § 10 is to enforce arbitration awards.The Supreme Judicial Court reversed the Superior Court's order, granting the committee's motion to dismiss and denying the union's motion for judgment on the pleadings. The court ordered that the arbitration award be confirmed. View "Boston Teachers Union, Local 66, American Federation of Teachers, AFL-CIO v. School Committee of Boston" on Justia Law

The case involves the defendant, David E. Canjura, who was arrested by Boston police officers on July 3, 2020, after an altercation with his girlfriend. During a search incident to the arrest, officers found a spring-assisted knife on Canjura. He was charged with carrying a dangerous weapon under G. L. c. 269, § 10 (b), and assault and battery on a family or household member. Canjura conceded the knife met the statutory definition of a switchblade but challenged the constitutionality of the statute under the Second Amendment.In the Boston Municipal Court, Canjura filed a motion to dismiss the charge, arguing that the statute violated his Second Amendment rights. The judge denied the motion, and Canjura entered a conditional plea, reserving his right to appeal. The court accepted his plea and placed him on administrative probation, while the assault and battery charge was dismissed at the Commonwealth's request. Canjura appealed, and the Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and applied the two-part test from New York State Rifle & Pistol Ass'n v. Bruen. The court first determined that switchblades are "arms" under the Second Amendment, as they fit historical definitions and were commonly used for lawful purposes at the time of the founding. The court then examined whether the statute was consistent with the nation's historical tradition of arms regulation. Finding no historical analogues to justify the regulation of switchblades, the court concluded that G. L. c. 269, § 10 (b), violated the Second Amendment. The court reversed the denial of Canjura's motion to dismiss, vacated his admission to sufficient facts, and ordered judgment to enter for the defendant on the dangerous weapon charge. View "Commonwealth v. Canjura" on Justia Law

The defendant was convicted of first-degree murder for the stabbing death of his ex-girlfriend, Kathryn Mauke. The defendant and the victim had dated on and off for several years, but the victim ended the relationship in December 2014. On February 11, 2015, the defendant left work early, walked to the victim's home, and stabbed her thirty-two times. The defendant's primary defense at trial was that he was not criminally responsible due to mental illness, which the jury rejected.The case was initially tried in the Superior Court, where the defendant was found guilty of first-degree murder on theories of deliberate premeditation and extreme atrocity or cruelty. The defendant filed a motion for a new trial, arguing that the testimony of two incarcerated informants was unreliable and that his trial counsel was ineffective. The motion was denied by the same judge who presided over the trial. The defendant then appealed both his conviction and the denial of his motion for a new trial.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the testimony of the two incarcerated informants was permissible and declined to create a new rule requiring reliability hearings for such testimony. However, the court mandated supplemental jury instructions for future cases involving incarcerated informants. The court also found that the defendant's trial counsel provided effective assistance and that the prosecutor's statements during closing arguments were proper. The court concluded that the defendant's sentence of life without parole was unconstitutional based on a recent decision, Commonwealth v. Mattis, and modified the sentence to allow for parole eligibility after thirty years. The court affirmed the conviction and the denial of the motion for a new trial. View "Commonwealth v. Lacrosse" on Justia Law

Two non-domiciliary companies, S&H Independent Premium Brands East, LLC, and S&H Independent Premium Brands West, LLC, import and distribute European alcoholic beverages in the United States. They hold certificates of compliance under Massachusetts General Laws Chapter 138, Section 18B, allowing them to sell alcoholic beverages to licensed wholesalers in Massachusetts. In 2019, an Austrian malt beverage producer, Stiegl Getränke & Service GmbH & Co. KG, terminated its distribution agreement with S&H without prior notice and entered into a new agreement with another distributor, Win-It-Too, Inc.S&H filed a petition with the Alcoholic Beverages Control Commission (ABCC), alleging that Stiegl violated Massachusetts General Laws Chapter 138, Section 25E, which prohibits suppliers from refusing to sell to any licensed wholesaler without good cause. The ABCC dismissed the petition, stating that Section 25E protections apply only to wholesalers licensed under Section 18, not to certificate holders under Section 18B. S&H then sought judicial review in the Superior Court, which upheld the ABCC's decision, agreeing that Section 25E protections do not extend to Section 18B certificate holders.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The Court held that the term "any licensed wholesaler" in Section 25E refers only to wholesalers licensed under Section 18, not to certificate holders under Section 18B. The Court also concluded that this interpretation does not violate the dormant commerce clause of the United States Constitution, as Section 18B certificate holders and Section 18 licensed wholesalers serve different roles in the regulatory framework. Therefore, the ABCC's decision to dismiss S&H's petition was upheld. View "S&H Independent Premium Brands East, LLC v. Alcoholic Beverages Control Commission" on Justia Law

The defendant was charged with assault and battery on a family or household member and was detained pretrial. While awaiting trial, he made two recorded phone calls to his fiancée, the alleged victim, advising her not to cooperate with authorities. He suggested that if she did not testify, the case against him would weaken. The fiancée expressed concerns about losing her housing and custody of her children due to police and Department of Children and Families (DCF) involvement. The defendant reassured her that things would improve if she followed his advice.The case was initially heard in the Lynn Division of the District Court Department, where the defendant was found guilty of witness intimidation under G. L. c. 268, § 13B. The judge denied the defendant's motion for a required finding of not guilty. The defendant appealed, and the Appeals Court affirmed the conviction. The Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed whether the defendant's statements constituted an offer or promise of anything of value to dissuade his fiancée from testifying. The court found that the Commonwealth failed to prove beyond a reasonable doubt that the defendant's vague assurances about their relationship and the potential end of the DCF investigation constituted a bribe. The court noted that the defendant did not have the power to influence the DCF investigation and that his statements did not amount to a quid pro quo arrangement. Consequently, the court reversed the conviction, set aside the finding, and ordered that judgment be entered for the defendant. View "Commonwealth v. Bellard" on Justia Law

A juvenile was indicted as a youthful offender for unarmed carjacking, unarmed assault with intent to rob, and assault and battery on an elder. The charges stemmed from an incident where the juvenile, after escaping from a secure facility, attacked an elderly man and stole his car. The juvenile pleaded guilty and was sentenced to two years in a house of correction followed by five years of probation.The Juvenile Court initially sentenced the juvenile to a house of correction, but after multiple probation violations, including missing appointments and being involved in new offenses, the court sentenced him to State prison. The juvenile appealed the sentence, arguing it was unlawful and that the judge did not adequately consider his well-being and the impact of recent literature on juvenile brain development.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the juvenile's sentence was lawful under G. L. c. 119, § 58, which allows for adult sentences, including State prison, for youthful offenders. The court determined that the Juvenile Court judge had appropriately considered the juvenile's criminal history, noncompliance with probation, and the need for public safety. The court also concluded that the judge did not need to make specific written findings on the impact of juvenile brain development literature.Additionally, the Supreme Judicial Court held that the Appellate Division of the Superior Court is authorized to review sentences to State prison imposed by the Juvenile Court on youthful offenders. This ensures that youthful offenders have the same procedural safeguards as adult criminal defendants. The court affirmed the juvenile's sentence and allowed for the appeal to the Appellate Division. View "Commonwealth v. Y." on Justia Law

The juvenile in this case was on probation after being adjudicated as a youthful offender for breaking and entering a vehicle with intent to commit a felony. While on probation, he began experiencing severe mental health issues, including hallucinations and delusions, which led him to obtain a firearm illegally. His mother called the police, and he was found in possession of a loaded firearm without a license. This led to new criminal charges and a notice of probation violation for not obeying state laws.The Juvenile Court judge found that the juvenile violated his probation by possessing the firearm and revoked his probation, sentencing him to incarceration. The judge ruled that the defense of lack of criminal responsibility was not available in probation violation hearings but considered the juvenile's mental illness in determining the disposition. The juvenile appealed, arguing that due process requires allowing the defense of lack of criminal responsibility in probation violation hearings.The Supreme Judicial Court of Massachusetts reviewed the case and held that the affirmative defense of lack of criminal responsibility is not required in probation violation hearings. The court reasoned that the primary inquiry in such hearings is whether the probationer violated a condition of probation, not whether the probationer is criminally responsible. However, the court acknowledged that evidence of mental illness is relevant to determining whether a violation was willful and in deciding the appropriate disposition. The court affirmed the lower court's decision, finding no error in the judge's ruling or abuse of discretion in revoking the juvenile's probation and imposing a sentence of incarceration. View "Commonwealth v. Z." on Justia Law