Justia Massachusetts Supreme Court Opinion Summaries

In this case involving a consequence of the evidence tampering by Sonja Farak, a chemist at the State Laboratory Institute at the University of Massachusetts at Amherst, the Supreme Judicial Court held that a defendant who qualified for an enhanced sentence due to a subsequently vacated predicate offense that had been tainted by Farak's misconduct may challenge the guilty plea without being exposed to a harsher sentence than that which he received in exchange for his plea.Defendant was indicted on two counts alleging aggravated statutory rape and as a habitual criminal, with two drug offenses on his prior record as the predicate convictions. Defendant pleaded guilty to lesser charges without the habitual offender enhancements. Defendant was later identified as a "Farak defendant," and one of his prior drug convictions was vacated. Before seeking to withdraw his guilty plea, Defendant requested a ruling that if he succeeded in withdrawing his plea he would not be subject to a harsher punishment as the result of a reprosecution of the rape charges. The superior court judge asked whether protections from harsher punishment established for "Dookhan defendants" apply to "Farak defendants" challenging Farak-related predicate offenses that resulted in enhanced sentences on subsequent convictions. The Supreme Judicial Court answered the question in the positive. View "Commonwealth v. Claudio" on Justia Law

In this wrongful death action, the Supreme Judicial Court affirmed the judgment of the superior court granting summary judgment in favor of Defendant based on the release from liability and covenant not to sue that the decedent signed before his death, holding that the beneficiaries of a wrongful death action have rights that are derivative of, rather than independent from, any claim the decedent could have brought for the injuries causing his death.The decedent, a certified open-water scuba diver, drowned while participating in a promotional diving equipment sponsored by Diving Unlimited International, Inc. (DUI). The decedent signed a release from liability prior to participating in the event. Plaintiff, in her capacity as the decedent's personal representative, sued DUI and Defendant, a DUI agent, for the benefit of the decent's statutory beneficiaries. Plaintiff settled with all defendants other than Defendant. The superior court then granted summary judgment in favor of Defendant, concluding that the waivers the decedent signed were valid and thus precluded any recovery on behalf of the decedent's beneficiaries, who had no rights independent of the decedent's cause of action, which was waived. The Supreme Judicial Court affirmed, holding that the valid waivers signed by the decedent precluded Plaintiff from bringing a lawsuit for the benefit of the statutory beneficiaries. View "Doherty v. Diving Unlimited International, Inc." on Justia Law

In this wrongful death action brought against a nursing home notwithstanding the existence of an arbitration agreement between the decedent and the nursing home the Supreme Judicial Court answered two certified questions by holding that the Legislature intended wrongful death actions to be derivative of the decedent's own cause of action and that, under the circumstances of this case, the arbitration agreement between the decedent and the nursing home controlled the decedent's statutory beneficiaries.After the decedent died in a nursing home, Plaintiff, her daughter, brought this wrongful death action. The United States Court of Appeals for the First Circuit certified two questions to the Supreme Judicial Court. The Supreme Court answered (1) the wrongful death statute, Mass. Gen. Laws ch. 229, 2, provides rights to statutory beneficiaries derivative of, rather than independent from, what would have been the decedent's action for the injuries causing her death; and (2) the arbitration clause in this case was enforceable. View "GGNSC Administrative Services, LLC v. Schrader" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting summary judgment and dismissing Plaintiffs' action seeking compensation for what it alleged was a taking, by the Town of Sturbridge, of certain property, holding that the superior court judge correctly concluded that Plaintiffs did not establish a taking or any right to compensation or damages.Plaintiffs, trustees of a trust, commenced an action against the Town seeking declarations concerning the Town's right to discharge water onto trust property. A judge declared that the Town had obtained a prescriptive easement on the property to discharge storm water through a town culvert onto and across the property. Plaintiffs then brought this action seeking compensation, arguing that the easement amounted to a taking for which it was entitled to compensation. A judge allowed the Town's motion for summary judgment. The Supreme Judicial Court affirmed, holding that Plaintiffs had no basis on which to claim a taking because the Town acquired the right to discharge storm water onto the property via the prescriptive easement. View "Gentili v. Town of Sturbridge" 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 Petitioner's claim could adequately be resolved by the appeals court.Petitioner pleaded guilty to an indictment alleging sex offenses. Petitioner's probation was later revoked, and the Commonwealth filed a petition to commit Petitioner as a sexually dangerous person (SDP). Petitioner moved to dismiss the SDP petition on the ground that, at the time it was filed, he was not a "prisoner" as defined by Mass. Gen. Laws ch. 123A, 12(b) because the release date had been revised. The motion was denied. Petitioner then filed this petition under Mass. Gen. Laws ch. 211, 3, alleging that the Commonwealth cannot demonstrate that he was a prisoner at the time his discharge petition was filed. A single justice denied relief. The Supreme Judicial Court affirmed, holding that the single justice correctly concluded that the ordinary appellate process provided an adequate remedy. View "Brace v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the decision of the single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3 seeking an order requiring a single justice of the appeals court to state findings and more detailed reasons for denying a prior petition for interlocutory review that she had filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that the petition was properly denied.Petitioner sought interlocutory review from a single justice of the appeals court by various orders in a civil action that she had commenced and which was pending in the superior court. Petitioner filed a petition in the appeals court, and the appeals court single justice denied the petition. Petitioner then brought this action. The Supreme Judicial Court denied relief, holding that Petitioner was not entitled to further review of the single justice's order. View "Montanez v. Flahive" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the court denying Plaintiff's requests for declaratory relief pursuant to Mass. Gen. Laws ch. 231A, 1, holding that the single justice properly denied relief.In his petition for declaratory relief Plaintiff requested to have the judge removed from his criminal matter and sought a general declaration that the judge should not sit on any criminal matters in Bristol County. The single justice denied relief. The Supreme Judicial Court affirmed, holding (1) because Plaintiff pleaded guilty, disposing of the criminal charge, Plaintiff's request to have the judge removed from his criminal matter was moot; and (2) Plaintiff had no right as a matter of law to seek an order compelling a judge's recusal from any case other than his own. View "Murphy v. Superior Court" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion in denying relief.Petitioner was convicted of multiple counts of larceny over $250. Petitioner's appeal was ultimately dismissed for lack of prosecution. Petitioner later filed his Mass. Gen. Laws ch. 211, 3 petition seeking an order dismissing the underlying criminal charges on the grounds that his appeal was deliberately blocked by the appeals court and others. A single justice denied relief. The Supreme Judicial Court affirmed, holding that Petitioner was not entitled to review pursuant to Mass. Gen. Laws ch. 211, 3. View "Kyricopoulos v. Commonwealth" on Justia Law

The Supreme Judicial Court held that possession of an open container of alcohol in a motor vehicle is a civil motor vehicle infraction rather than a criminal offense, thus overruling Commonwealth v. Giannino, 371 Mass. 700 (1977), in which the Court held that automobile law violations must encompass the "operation or control" of a motor vehicle.Defendant was charged with possessing open container of alcohol in a motor vehicle in violation of Mass. Gen. Laws ch. 90, 20, and other offenses. Defendant argued that the open container charged constituted a civil infraction, rather than a criminal offense. The trial court disagreed, concluding that it was a criminal offense. A jury found Defendant guilty. At issue was whether an open container violation fits within the definition of a "civil motor vehicle infraction," which is defined as an automobile law violation for which the maximum penalty does not provide for imprisonment. The Supreme Court affirmed after analyzing the legislative history and plain language of the open container statute, holding that a violation of Mass. Gen. Laws ch. 90, 24I is an automobile law violation and thus a civil motor vehicle infraction. View "Commonwealth v. Mansur" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice denying Defendant's Mass. Gen. Laws ch. 211, 3 petition for bail review, holding that because the bail determinations were properly made and no violation of Defendant's rights occurred, the single justice did not err or abuse her discretion in denying Defendant's petition seeking review of the bail determination.Defendant's first trial for murder in the first degree and ended in a mistrial. Defendant subsequently filed a motion to dismiss the indictment on double jeopardy grounds, but the motion was denied. A single justice denied Defendant's Mass. Gen. Laws ch. 211, 3 petition seeking review of that ruling, and the Supreme Judicial Court affirmed. While Defendant's appeal was pending, bail was set in the cash amount of $250,000. After Defendant unsuccessfully filed a motion for bail review he filed a petition pursuant to Mass. Gen. Laws ch. 211, 3 for bail review. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice did not err or abuse her discretion in denying the petition. View "Pinney v. Commonwealth" on Justia Law