Justia Massachusetts Supreme Court Opinion Summaries

The plaintiffs, Jeffrey Cubberley and Philip Seaver, filed a lawsuit against The Commerce Insurance Company, seeking declaratory relief and compensation for alleged breach of contract. They claimed that Commerce was obligated to cover "inherent diminished value" (IDV) damages to their vehicles, which were damaged in collisions caused by Commerce's insured drivers. Commerce paid for the repairs but refused to compensate for IDV damages, leading the plaintiffs to argue that their vehicles were worth less in the resale market post-repair.The plaintiffs initially filed their lawsuit in the Superior Court, which was later transferred to the business litigation session. The case was stayed pending the outcome of McGilloway v. Safety Ins. Co., which held that IDV damages were recoverable under the 2008 standard Massachusetts automobile policy. After the stay was lifted, the plaintiffs filed a second amended complaint. Commerce moved to dismiss the claims, arguing that the 2016 standard policy excluded IDV damages. The motion judge granted the dismissal, concluding that the policy did not cover IDV damages and that the plaintiffs failed to allege facts suggesting an entitlement to relief. The plaintiffs appealed, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court affirmed the dismissal, holding that the plaintiffs lacked standing to pursue their breach of contract claims because they had not obtained final judgments against the insureds, as required by G. L. c. 175, § 113, and G. L. c. 214, § 3 (9). Additionally, the court found that part 4 of the 2016 standard policy explicitly excluded coverage for IDV damages to third-party vehicles. The court also determined that neither G. L. c. 90, § 34O, nor the decision in McGilloway provided a legal basis requiring insurers to cover IDV damages under the 2016 standard policy. Thus, the plaintiffs' complaint did not plausibly establish an entitlement to relief. View "Cubberley v. The Commerce Insurance Company" on Justia Law

In this case, the defendant was on trial for murder. During jury deliberations, an argument between two jurors led to allegations of racial bias. The judge conducted a limited inquiry into the matter but did not fully investigate the allegations. The defendant was convicted of murder in the second degree, unlawful possession of a firearm, and unlawful possession of a loaded firearm.The case was initially tried in the Superior Court Department, where the defendant was found guilty. The defendant appealed, and the Appeals Court affirmed the conviction. The Supreme Judicial Court then granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the trial judge's limited inquiry into the allegations of racial bias was insufficient. The court held that the judge should have conducted a more thorough investigation to determine whether the alleged racial bias affected the jury's impartiality. The court emphasized the importance of ensuring a fair and impartial trial, free from racial bias.As a result, the Supreme Judicial Court vacated the defendant's convictions and remanded the case for a new trial. The court's main holding was that the trial judge's failure to adequately investigate the allegations of racial bias created a substantial risk of a miscarriage of justice, warranting a new trial. View "Commonwealth v. Vasquez" on Justia Law

A juvenile was involved in an altercation at the Barnstable District and Juvenile Court, where he was charged with disorderly conduct and assault and battery. The incident was captured on video, showing the juvenile and the victim engaging in a physical fight. The juvenile had a prior continuance without a finding (CWOF) after admitting to sufficient facts for an assault and battery charge.The Juvenile Court adjudicated the juvenile delinquent on both charges and sentenced him to one year of probation for each. The juvenile appealed, arguing that the court lacked jurisdiction over the disorderly conduct charge because a CWOF after an admission to sufficient facts should not count as a prior offense under G. L. c. 119, § 52. The Appeals Court did not review the case as it was transferred to the Supreme Judicial Court.The Supreme Judicial Court held that a CWOF entered after an admission to sufficient facts is sufficient to establish a first offense under § 52. Therefore, the Juvenile Court had jurisdiction over the disorderly conduct charge. The court also found that the evidence was sufficient to support the juvenile's adjudications of delinquency for both disorderly conduct and assault and battery. The court affirmed the adjudications, concluding that the juvenile did not act in self-defense and that his actions met the criteria for disorderly conduct. View "Commonwealth v. Fayad F." on Justia Law

The Commonwealth sought to civilly commit a prisoner, previously convicted of a sexual offense, as a "sexually dangerous person" (SDP) under Massachusetts law. The process required expert testimony to establish probable cause and qualified examiners to determine if the case should proceed to trial. The plaintiff, George Mackie, was initially adjudicated as an SDP based on expert reports and testimony, but this decision was later vacated on appeal due to prejudicial error.Mackie then filed separate civil actions against Dr. Katrin Rouse-Weir, a probable cause expert, and Dr. Robert Joss, a qualified examiner, alleging they submitted false reports and testimony. Both defendants moved to dismiss the complaints, claiming immunity. Superior Court judges granted the motions, concluding that the defendants were entitled to absolute quasi-judicial immunity. Mackie appealed these decisions.The Appeals Court reversed the dismissals, ruling that the experts were entitled only to qualified immunity, not absolute quasi-judicial immunity. The Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court held that qualified examiners like Joss are entitled to absolute quasi-judicial immunity due to their essential and independent role in the judicial process. The court also concluded that probable cause experts like Rouse-Weir are protected by the litigation privilege, which shields them from liability for their statements made during judicial proceedings. Consequently, the court affirmed the Superior Court judgments dismissing Mackie's complaints against both experts. View "Mackie v. Rouse-Weir" on Justia Law

The defendant was convicted of second-degree murder for the killing of Paul Finegan at a backyard birthday party in Springfield. The defendant arrived at the party, where the victim, who was uninvited, became upset upon seeing him. After a brief argument, the defendant shot the victim in the head and fled the scene. The victim was unarmed, and the defendant did not testify at trial. The defense argued that the eyewitnesses were not credible and had been pressured by the police.The case was initially tried in the Superior Court, where the defendant was found guilty of second-degree murder. The defendant filed a motion for a new trial, arguing that a voir dire question asked by the prosecutor during jury selection was improper and deprived him of an impartial jury. The trial judge denied the motion, and the Appeals Court affirmed the conviction and the denial of the motion for a new trial.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the prosecutor's voir dire question, which asked prospective jurors if they could convict the defendant based on eyewitness testimony without forensic evidence, was improper. However, the court concluded that this error did not create a substantial risk of a miscarriage of justice. The court noted that the evidence against the defendant was overwhelming, and the jury had been properly instructed on the burden of proof and the evaluation of eyewitness testimony. The court affirmed the defendant's conviction and the order denying his motion for a new trial. View "Commonwealth v. Montgomery" on Justia Law

A Braintree tobacco compliance officer observed an open container of Jazz brand "Black & Mild" cigars on display behind the cash register of a convenience store. The Board of Health of Braintree found that the store violated state and local tobacco laws by offering a flavored tobacco product for sale and imposed a $1,000 fine. The store argued that it did not intend to sell the product and that its point-of-sale system would have prevented the sale. The store also contended that the board acted outside its authority in imposing the fine and that the proceedings were procedurally defective.The Superior Court reviewed the case and upheld the board's decision, finding substantial evidence to support the board's conclusion that the store offered the cigars for sale. The court also determined that the board had the authority to impose the fine administratively and that no procedural irregularities fatally marred the board's actions. The store appealed the decision.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the Superior Court's judgment. The court held that the store's placement and display of the cigars supported the board's finding that the product was being offered for sale. The court also concluded that the legislative and regulatory scheme governing the sale of tobacco products in Massachusetts permits local boards of health to enforce the regulations and impose mandatory penalties. The court found no procedural deficiencies that would invalidate the board's actions. View "Cumberland Farms, Inc. v. Board of Health of Braintree" on Justia Law

The case involves a dispute between partners in a limited partnership formed to develop and operate an affordable housing project in Boston. The financing and structure of the project were driven by the Low Income Housing Tax Credit (LIHTC) program, which incentivizes private investment in affordable housing through tax credits. The partnership agreement included a right of first refusal (ROR) for the nonprofit general partner to purchase the property at a below-market price after the compliance period.In the Superior Court, the judge ruled on cross motions for summary judgment, concluding that the investor limited partner, AMTAX, did not have a consent right over a sale to the nonprofit general partner under the ROR agreement. However, the judge also ruled that the purchase price under the ROR agreement must include the limited partners' exit tax liability. The judge dismissed the remaining claims and counterclaims due to lack of evidentiary support or as a consequence of these rulings.The Supreme Judicial Court of Massachusetts reviewed the case. The court affirmed the lower court's decision, holding that AMTAX's consent was not required for the preliminary steps leading to a sale under the ROR agreement. The court also held that the limited partners' exit taxes were "attributable to" the sale of the property and must be included in the purchase price. The court found that the notice of consent rights recorded by AMTAX was accurate and did not constitute slander of title or tortious interference. Consequently, the plaintiffs' claims for breach of contract, breach of the implied covenant of good faith and fair dealing, tortious interference, slander of title, and violation of G. L. c. 93A were dismissed. The judgment was affirmed. View "Tenants' Development Corporation v. Amtax Holdings 227, LLC" on Justia Law

The case involves a dispute over the construction of a substation by Park City Wind LLC (PCW) that will connect an offshore wind farm to the New England electric grid. Jacqueline Johnson, the petitioner, lives near the proposed substation site and raised concerns about the noise impact from the substation, which includes loud step-up transformers. PCW presented expert testimony and reports to the Energy Facilities Siting Board (the board) indicating that design features would mitigate the noise impact, keeping it within the allowable increase of ten A-weighted decibels (dBA) set by the Department of Environmental Protection (DEP).The board approved PCW's petition to construct the substation, subject to several conditions, including preconstruction and postconstruction reviews to ensure the noise levels at Johnson's home would not exceed an eight dBA increase. Johnson was allowed to participate fully in the administrative process, including discovery, briefing, and cross-examination of PCW's experts. The board required PCW to confirm that the predicted noise levels would not be exceeded once the equipment specifications were known and to implement additional noise mitigation measures if necessary.The Supreme Judicial Court of Massachusetts reviewed the case. Johnson argued that the board's decision was not supported by substantial evidence because it relied on aggressive sound level design specifications for yet-to-be-manufactured equipment. The court concluded that Johnson failed to meet the heavy burden required to overturn the board's decision, which was supported by substantial evidence, including expert testimony and industry-standard sound modeling. The court also found that the board's conditional approval, requiring preconstruction and postconstruction compliance filings, was lawful and within the board's statutory authority. The court affirmed the board's decision. View "Johnson v. Energy Facilities Siting Board" on Justia Law

The case involves the Massachusetts Bay Transportation Authority (MBTA) Communities Act, which mandates that cities and towns with local access to MBTA services adopt zoning laws to provide at least one district of multifamily housing "as of right" near their MBTA facilities. The town of Milton, which has four MBTA stations, voted down a proposed zoning scheme to comply with the act. The Attorney General then sued the town to enforce the act.The Supreme Judicial Court for the county of Suffolk reviewed the case. The town initially took steps to comply with the act, including hiring a consultant and submitting an action plan to the Executive Office of Housing and Livable Communities (HLC). However, a town-wide referendum ultimately rejected the proposed zoning bylaw. The Attorney General filed a complaint seeking declaratory and injunctive relief to enforce compliance with the act.The Supreme Judicial Court of Massachusetts held that the MBTA Communities Act is constitutional and that the Attorney General has the authority to enforce it. However, the court found that the HLC did not comply with the Administrative Procedure Act (APA) when promulgating the guidelines, rendering them ineffective. The court granted declaratory relief in part and dismissed the remaining claims, directing the single justice to enter a declaratory judgment consistent with the opinion. View "Attorney General v. Town of Milton" on Justia Law

In July 2019, the defendant was charged with one count of possession of child pornography. While at a supermarket, a mother observed the defendant pointing his cell phone at an unusual angle towards her and her daughters. The defendant denied taking photos and showed the mother his phone, which contained several images of clothed women from the waist down. The mother reported the incident to the police. Officer Columbus, who was present at the store, investigated and found numerous images of clothed women on the defendant's phone. Upon further inspection, with the defendant's consent, Columbus discovered images she believed to be child pornography. The defendant admitted to possessing child pornography but claimed he took screenshots to report them to website administrators, though he had not done so.The defendant was found guilty in a bench trial in the District Court and sentenced to six months in a house of correction, suspended for two years. He appealed, arguing that the trial judge erred by allowing a lay witness to testify about the technology used to extract data from his cell phone, which he contended required expert testimony.The Supreme Judicial Court of Massachusetts reviewed the case. The court agreed that the trial judge abused his discretion by allowing some of the contested testimony from Officer McLaughlin, who explained the Cellebrite system used to extract data from the defendant's phone. However, the court concluded that the error was nonprejudicial. The court found that the evidence against the defendant was overwhelming, including testimony from multiple officers and the defendant's own admission. Additionally, the images were properly admitted through McLaughlin's lay testimony. Therefore, the court affirmed the defendant's conviction. View "Commonwealth v. Cronin" on Justia Law