Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the superior court denying Defendant's motion to compel arbitration of Plaintiff's claims that Defendant had engaged in improper debt collection practices and debt collection regulations, holding that there was no error in the denial of Defendant's motion to compel arbitration.Plaintiff allegedly owed debt to Enterprise Rent-A-Car Company of Boston, LLC for damage to a rental vehicle. Enterprise assigned the debt to Defendant for collection. Plaintiff filed a class action complaint against Defendant, alleging that Defendant made too frequent phone contact with him and other debtors. Defendant sought to compel arbitration of Plaintiff's claims pursuant to the rental contract between Plaintiff and Enterprise. The superior court denied the motion to compel. The Supreme Court affirmed, holding that reasonable minds could differ as to whether the arbitration provision in the contract was applicable to claims brought against Defendant, and therefore, Defendant did not put forth the clear and definite evidence of intent that it must to be entitled to enforce the arbitration provision as a third-party beneficiary. View "Landry v. Transworld Systems Inc." on Justia Law

The Supreme Judicial Court affirmed the order of the superior court granting summary judgment to Northeastern University on Plaintiff's negligence-related claims stemming from a nonconsensual encounter with a fellow student, holding that, under the circumstances, Northeastern had no duty to protect Plaintiff.In her complaint, Plaintiff alleged that Northeastern negligently failed to prevent and contributed to the occurrence of the sexual assault. Plaintiff further asserted tort, contract, and statutory claims alleging that Northeastern failed adequately to respond to the incident. The Supreme Judicial Court affirmed, holding (1) a special student-university relationship between Plaintiff and Northeastern existed, but Northeastern owed no duty to protect Plaintiff because Northeastern could not reasonably have foreseen that, absent some intervention on its part, Plaintiff would be subjected to a criminal act or other harm; and (2) there was no error in the motion judge's conclusions regarding Plaintiff's statutory or contract claims. View "Helfman v. Northeastern University" on Justia Law

The Supreme Judicial Court reversed the order of the superior court judge allowing Defendant's motion to suppress statements he made to police officers, holding that Defendant was not subjected to custodial interrogation while speaking with the police officers and that the statements were otherwise voluntary.Defendant was placed under arrest for the removal of human remains from the Worcester cemetery. Defendant filed a motion to suppress statements he made to Hartford police officers, arguing that the statements were made under custodial interrogation without Miranda warnings and that they were involuntary. The motion judge allowed the motion to suppress. The Supreme Judicial Court reversed, holding (1) Defendant was not in custody when he made his statements to the police officers, and therefore, Miranda warnings were not required; and (2) there was no indication that Defendant's statements were involuntarily made. View "Commonwealth v. Medina" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree, holding that there was no prejudicial error in the proceedings below, and there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or to order a new trial.Specifically, the Supreme Judicial Court held (1) the motion judge did not err in denying Defendant's motion to suppress his statement to the police; (2) an indisputably gruesome photograph should not have been admitted into evidence, but there was no cause to disturb the verdict; (3) there was no error in the absence of a sua sponte instruction on lost evidence; (4) the judge did not err in admitting into evidence two knives; (5) certain statements in the prosecutor's closing argument were improper, but the improprieties did not require a new trial; and (6) there were no grounds on which to reduce the degree of guilt or to order a new trial. View "Commonwealth v. Walters" on Justia Law

On appeal from a federal appellate court's decision that the Federal Medicare scheme prohibits State Medicaid agencies, including MassHealth, from receiving funds from Medicare, the Supreme Judicial Court ordered that this case be remanded for modification of the declaratory judgment, holding that MassHealth demonstrated a sufficient change in circumstances to warrant modification to allow MassHealth to seek reimbursement where the liable third party is Medicare.In Atlanticare Medical Center v. Commissioner of the Division of Medical Assistance, 439 Mass. 1, 3, 5 (2003) (Altanticare I), the Supreme Judicial Court concluded that the Federal Medicaid scheme tasked the State Medicaid agency, not individual providers, with seeking reimbursement from liable third-party insurers, including Medicare. When the Center for Medicare & Medicaid Services (CMS) refused to issue reimbursements from Medicare to MassHealth, MassHealth brought suit. In 2011, the United States Court of Appeals for the First Circuit held that the Federal Medicare scheme prohibited MassHealth from receiving funds from Medicare. Therefore, a Federal Medicare regulation was amended to acknowledge the practice of State Medicaid agencies obtaining Medicare reimbursements through providers, rather than seeking such reimbursements directly from Medicare. MassHealth sought to modify the declaratory judgment and restore its ability to obtain reimbursements from providers, rather than liable third parties. The Supreme Judicial Court remanded the case for modification of the judgment, holding that changed circumstances required modification. View "Atlanticare Medical Center v. Division of Medical Assistance" on Justia Law

The Supreme Judicial Court reversed the order granting judgment to Plaintiffs on their claims under the Wage Act, Mass. Gen. Laws ch. 149, 148, 150, and the Prevailing Wage Act, Mass. Gen. Laws ch. 149, 26-27H, on the ground that by violating the Prevailing Wage Act, Defendants violated the Wage Act as well, holding that Plaintiffs may not avoid the limitations that the Prevailing Wage Act places on their recovery by pursuing an otherwise duplicative claim under the Wage Act.Plaintiffs asserted that for several years they were paid less than the wages required by the Prevailing Wage Act. The motion judge granted partial summary judgment for Plaintiffs, concluding that Defendants' "chronic underpayment" of Plaintiffs constituted a plain violation of the Prevailing Wage Act and that Defendants' failure to pay Plaintiffs at the prescribed wage rates also constituted a violation of the Wage Act. The Supreme Judicial Court reversed the order allowing Plaintiffs' motion for partial summary judgment, holding that, whereas the Prevailing Wage Act and the Wage Act provide conflicting mechanisms to recover the same underpayment of wages, Plaintiffs may, in this instance, recover solely under the Prevailing Wage Act. View "Donis v. American Waste Services, LLC" on Justia Law

The Supreme Judicial Court held that a juvenile court judge has authority to hear a motion to dismiss as part of a transfer hearing after arraignment and that a juvenile does not have an automatic right of appeal under Mass. Gen. Laws ch. 211, 3 where the motion is denied.A juvenile argued that the prosecutor improperly delayed bringing criminal charges against her until after her nineteenth birthday and filed a motion to dismiss for prosecutorial delay. The juvenile court judge denied the juvenile's motion to dismiss, determining that the motion should be heard after the transfer hearing was complete and any subsequent complaint was issued in an adult court. The juvenile filed a petition for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3. The single justice denied the petition, and the juvenile was arraigned. The Supreme Judicial Court remanded the case, holding (1) with certain exceptions, a juvenile court judge generally has no authority to dismiss a complaint prior to arraignment; and (2) a juvenile has no automatic right to an interlocutory appeal from the denial of a motion to dismiss for bad faith or inexcusable delay. View "Ulla U. v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of the Land Court dismissing Plaintiffs' complaint challenging a dimensional zoning requirement, holding that Plaintiffs were not persons aggrieved for purposes of Mass. Gen. Laws ch. 40A, 17 and, therefore, lacked standing to challenge the decision of the zoning board of appeals.Plaintiffs' neighbors received a foundation permit to construct a single-family resident on property directly across the street from Plaintiffs' home. After the zoning board of appeals of Sherborn upheld the issuance of the permit Plaintiffs filed this complaint in the Land Court. The Land Court dismissed complaint for lack of standing, concluding that Plaintiffs were not aggrieved by the board's decision within the meaning of Mass. Gen. Laws 40A, 17. The Appeals Court reversed. The Supreme Judicial Court ordered dismissal of the complaint, holding that the Land Court judge did not err in deciding that Plaintiffs were not aggrieved by the board's decision and therefore lacked standing to pursue the appeal. View "Murchison v. Zoning Board of Appeals of Sherborn" on Justia Law

The Supreme Judicial Court affirmed the decision of the appellate tax board (board) upholding the Commissioner of Revenue's assessment of an additional Massachusetts estate tax based on the value of a qualified terminable interest property (QTIP) trust in computing a decedent's Massachusetts estate tax return, holding that there was not a constitutional or a statutory barrier to the assessment.Robert Chuckrow created a QTIP trust in New York. Adelaid Chuckrow (decedent) was the lifetime income beneficiary of the QTIP trust and deed domiciled in Massachusetts. The decedent's estate (estate) did not include the value of the QTIP trust assets in computing her Massachusetts estate tax return. After an audit, the Commission assessed an additional Massachusetts estate tax of almost $2 million based on the value of the QTIP assets. The board upheld the assessment. At issue before the Supreme Judicial Court was whether the intangible assets in the QTIP trust were includable in the gross estate of the decedent for purposes of calculating the Massachusetts estate tax under Mass. Gen. Laws ch. 65C, 2A(a). The Supreme Judicial Court affirmed, holding that the QTIP assets were includable in the estate for purposes of the Massachusetts estate tax. View "Shaffer v. Commissioner of Revenue" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and assault and battery and several related orders denying postconviction relief, holding that each of Defendant's claims lacked merit.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's pretrial motion to suppress digital camera images; and (2) the Commonwealth violated its obligation under article 36 of the Vienna Convention on Consular Relations to apprise Defendant of his article 36 rights to representation of counsel of his choice and court-appointed conflict-free counsel, but the error was neither constitutional nor structural. View "Commonwealth v. Fernandes" on Justia Law