Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the jury's verdict awarding Plaintiff damages after finding that Defendants violated Mass. Gen. Laws ch. 149, 148, 148A & 150 (the Wage Act) but vacated portions of the trial judge's final judgment, holding that the judge erred in his determination of the portion of the award subject to trebling under the Wage Act.Plaintiff, a former employee of Defendants, argued that Defendants failed to pay her the full amount of a commission that she had earned and by terminating her when she complained about it, resulting in her losing an additional commission. The jury found that Defendants violated the Wage Act and awarded Plaintiff damages. The Supreme Court reversed in part, holding (1) the jury's verdict was supported by the evidence, and therefore, the trial court properly denied Defendants' motion for judgment notwithstanding the verdict; but (2) the full amount of the commission that would have been due to Plaintiff had she not been terminated is a "lost wage" that must be trebled pursuant to the Wage Act. View "Parker v. EnerNOC, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Appellant's petition for relief under Mass. Gen. Laws ch. 211, 3, in which Appellant sought review of certain rulings in a personal injury action, holding that because of serious deficiencies in Appellant's petition, the single justice neither erred nor abused his discretion by denying extraordinary relief.The district court dismissed Appellant's complaint in the personal injury action, and Appellant's appeal was also dismissed. Two subsequent attempts to appeal were also dismissed. Appellant then brought this action under Mass. Gen. Laws ch. 211, 3 asserting, without any supporting documents or other substantiation, that the district court judge acted improperly. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice properly denied extraordinary relief due to significant deficiencies in Appellant's petition. View "Wilson v. Stop & Shop Supermarket Co., LLC" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Appellant's petition for extraordinary relief under Mass. Gen. Laws ch. 211, 3, in which Appellant sought relief from a judgment entered in a small claims case in the municipal court, holding that the single justice neither erred nor abused his discretion by denying relief.In the small claims case, Appellant alleged that two corporations violated Mass. Gen. Laws ch. 93A. The clerk-magistrate entered judgment for Defendants, concluding that Appellant had not proved that they were responsible for the damages he claimed. The Supreme Judicial Court affirmed, holding that Appellant's argument that the clerk-magistrate should have made detailed findings was unavailing because nothing in the statutes or rules governing small claims procedures required the clerk-magistrate to do so. View "Prince v. Obelisk, Inc." on Justia Law

In this case involving a final judgment entered against a professional corporation for the fraudulent activity of one of its associates, the Supreme Judicial Court held that, in the unique circumstances of this case, Plaintiff, who was defrauded by the associate, may pursue successor liability against the sole proprietorship of Defendant, the sole shareholder and officer of the professional corporation.Plaintiff was defrauded by the corporation's associate in a mortgage scam. Defendant was the sole shareholder and officer of the corporation, RKelley-Law, P.C. (the P.C.). After the entry of final judgment against the P.C. Defendant voted to wind up the corporation and, that same day, began operating his law practice as a sole proprietorship. Thereafter, the P.C. was placed into bankruptcy proceedings. Because the P.C. had no assets, Plaintiff sought to recover from Defendant personally. The district court granted summary judgment in favor of Defendant, concluding that the doctrine of successor liability could not be applied where the successor in interest was a natural person rather than a corporate entity. The court of appeals affirmed. The Supreme Judicial Court reversed, holding that because Defendant's sole proprietorship was a mere continuation of the former professional corporation Plaintiff may pursue successor liability against the proprietorship. View "Smith v. Kelley" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree and related crimes, holding that Defendant was not deprived of a meaningful defense due to the current law on criminal responsibility and that there was no reason to reduce the verdict under Mass. Gen. Laws ch. 28, 33E.At trial, defense counsel unsuccessfully claimed that a mental disorder caused Defendant to suffer delusions that compelled him to plan and commit the murder. On appeal, however, Defendant argued that the law on criminal responsibility made this defense not viable. Therefore, he argued he was deprived of a meaningful defense. The Supreme Judicial Court affirmed, holding (1) the trial judge did not commit reversible error by denying two motions filed by Defendant that advocated for a departure from the current la regarding the defense of a lack of criminal responsibility; and (2) while Defendant suffered from a qualifying mental disorder, he was nonetheless able to conform his actions to the law and to understand the wrongfulness of his actions. View "Commonwealth v. Loya" on Justia Law

The Supreme Judicial Court affirmed the decision of the Appellate Tax Board (the Board) upholding sales tax assessments for fees charged for subscriptions to use online software products, holding that the subscription fees were subject to sales tax.Appellant sold subscriptions for three online software products. The Commissioner of Revenue determined that Appellant's subscription fees constituted sales of software subject to sales tax and assessed sales tax against Appellant for the taxable periods April 2007 through June 2009 and October 2009 through December 2011. The Board upheld the sales tax assessments. The Supreme Judicial Court affirmed, holding that receipts from sales of subscriptions for the online software products were subject to Massachusetts sales tax. View "Citrix Systems, Inc. v. Commissioner of Revenue" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court allowing Defendant's motions to suppress evidence seized during an inventory search of his vehicle and his subsequent statements to police, holding that, where officers are aware that a passenger lawfully could assume custody of a vehicle, it is improper to impound the vehicle without first offering this option to the driver.Defendant, the driver of the vehicle in this case, was properly stopped for a motor vehicle violation and then arrested on an outstanding warrant. The vehicle's sole passenger was a duly licensed and qualified driver. The officers arranged for the vehicle to be impounded without inquiring of Defendant as to whether he preferred to have the passenger take custody of and move the vehicle. After conducting an inventory search the officers discovered Defendant's gun. The motion judge suppressed the gun and Defendant's statements, finding the impoundment to be unreasonable. The Supreme Judicial Court affirmed, holding that suppression was appropriate under the circumstances of this case. View "Commonwealth v. Goncalves-Mendez" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions entered by the trial court after a second trial, at which Defendant had different counsel, holding the second trial judge did not err in granting Defendant's motion for a new trial on the basis that Defendant's second attorney provided ineffective assistance of counsel.Defendant was charged with murder in the first degree and related offenses. Then the jury was unable to reach a verdict Defendant's first trial ended in a mistrial. The second trial resulted in Defendant being convicted. Defendant then filed a motion for a new trial, arguing that successor counsel's failure to call or investigate an alibi witness constituted constitutionally ineffective assistance of counsel. The second trial judge allowed the motion, determining that the testimony necessarily would be important to the jury's deliberations. The Supreme Judicial Court affirmed, holding that, under the circumstances, the judge was not unreasonable in finding successor counsel's performance ineffective, and the error was prejudicial. View "Commonwealth v. Diaz Perez" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of assault and battery causing serious bodily injury, holding that there was no error with respect to the seating of a blind individual on the jury and that the evidence was sufficient to support the conviction.Defendant's conviction stemmed from an incident in which Defendant, without warning, punched the victim in the face. On appeal, Defendant argued, among other things, that his right to a fair and impartial jury was violated because the blind juror that served on the jury was unable to see the physical evidence and had to have the documentary evidence read to him. The Supreme Judicial Court affirmed, holding (1) seating the blind juror was not an abuse of the trial judge's discretion; and (2) the evidence was sufficient to establish beyond a reasonable doubt that Defendant caused serious bodily injury to the victim. View "Commonwealth v. Heywood" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of discharging a firearm within 500 feet of a building, in violation of Mass. Gen. Laws ch. 269, 12E, and unlawful possession of a firearm, in violation of Mass. Gen. Laws ch. 269, 10(h), holding that that section 12E does not require any mens rea as to the element of discharge and that the trial judge properly declined to instruct on an exemption for temporarily holding a firearm.Defendant's convictions stemmed from an incident in which, while showing a firearm to one of his friends, Defendant accidentally discharged it in a home, shooting his friend through the hand. On appeal, Defendant argued that section 12E includes a mens rea requirement and that the trial judge erred in declining to instruct on an exemption for temporarily holding a firearm. The Supreme Court affirmed, holding (1) section 12E does not require any mens rea as to the element of discharge; and (2) the trial judge did not err in declining to give the requested instruction on the exemption for temporary possession. View "Commonwealth v. Kelly" on Justia Law