Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court reversed the order of the motion judge denying Defendant's motion to suppress evidence found in his motor vehicle following a search, holding that the exit order that precipitated the search of the vehicle was unjustified.A search of a box hidden inside the front passenger seat of the vehicle at issue revealed a large amount of cocaine and several large stacks of cash. Defendant was subsequently charged with trafficking in cocaine. Defendant moved to suppress the evidence, arguing that the search took place after an unlawful exit order. The superior court denied Defendant's motion to suppress. The Supreme Judicial Court reversed, holding that because the exit order was not lawfully issued the evidence obtained from the subsequent search should have been suppressed as fruit of the poisonous tree. View "Commonwealth v. Barreto" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions and the denial of his postconviction motions and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that any error in the proceedings below was harmless.Defendant was convicted of murder in the first degree on the theory of deliberate premeditation and related charges. Before the Supreme Judicial Court was Defendant's appeal from his convictions, from the denial of his motion for a new trial, and from the denial of a motion to reconsider the denial of his new trial motion. The Supreme Judicial Court affirmed, holding (1) Defendant was not entitled to relief on his argument that newly discovered medical records warranted a new trial; (2) trial counsel was not constitutionally ineffective; (3) that the trial judge did not commit reversible error in admitting evidence of the defendant's prior, failed attempts to purchase a firearm; and (4) there was no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce or set aside the jury's verdict of murder in the first degree. View "Commonwealth v. Don" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction and the denials of Defendant's two motions for a new trial and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that there was no error in the proceedings below.Specifically, the Court held (1) the trial court did not err by denying Defendant's motion for a required finding of not guilty; (2) Defendant did not receive ineffective assistance of counsel; (3) the trial judge did not err in admitting allegedly unduly prejudicial evidence, failing to sanction the Commonwealth for the alleged destruction of exculpatory evidence, and failing to recuse herself; and (4) because there was no error, any allegations of unpreserved cumulative error were without merit. View "Commonwealth v. Norris" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree and conspiracy to commit murder and declined to grant extraordinary relief under Mass. Gen. Laws ch. 278, 33E, holding that the trial judge did not abuse her discretion in admitting certain prior consistent statements and that there was no reason to grant a new trial or to reduce the verdict.A jury convicted Defendant of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty and of conspiracy to commit murder. Defendant appealed, arguing that the trial judge abused her discretion by allowing a State police trooper to testify to the prior statements of a key witness that were consistent with that witness's trial testimony. The Supreme Judicial Court affirmed and declined to exercise its authority to reduce the verdict or order a new trial, holding there was no error in the admission of the prior consistent statements. View "Commonwealth v. Morales" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court allowing Insurer's motion for summary judgment and dismissing Plaintiffs' action claiming that Insurer failed to effectuate a prompt, fair, and equitable settlement, holding that consent-to-settle clauses in professional liability policies do not violate Mass. Gen. Laws ch. 176D, 3(9)(f).Insurer issued a professional liability policy to Insured that contained a consent-to-settle clause. Plaintiffs sued Insured for engineering design errors in their house, and Insured refused to consent to settle. Plaintiffs then brought this action under Mass. Gen. Laws ch. 93A. The motion judge granted summary judgment in favor of Insured, concluding that the consent-to-settle clause in this case limited Insurer's ability to engage in further settlement practices with Plaintiffs once Insured refused to give Insurer consent to settle Plaintiffs' claims. The Supreme Judicial Court affirmed, holding that where Insurer made good faith efforts to investigate the claim and encourage Insured to settle and where Insurer's shortcomings did not proximately cause harm to Plaintiffs the superior court did not err in allowing Insurer's motion for summary judgment. View "Rawan v. Continental Casualty Co." on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the county court denying Petitioner's petition for relief in the nature of certiorari pursuant to Mass. Gen. Laws ch. 249, 4, holding that the single justice did not err or abuse her discretion in denying relief.Petitioner brought this action against Respondent alleging slander, libel, and intentional infliction of emotional distress. Petitioner sought to have the Attorney General disqualified from representing Respondent, but Petitioner's motion and subsequent motion for reconsideration of the issue were denied. Petitioner filed a petition pursuant to Mass. Gen. Laws ch. 231, 118 seeking review. The appeals court denied the petition on the basis that it was not timely filed. Petitioner then sought relief in the nature of certiorari. The Supreme Judicial Court denied relief, holding that Petitioner failed to demonstrate that his claims were not otherwise reviewable. View "Padmanabhan v. Cooke" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying Petitioner's petition for extraordinary relief under Mass. Gen. Laws ch. 211, 3, holding that Petitioner was not entitled to review pursuant to Mass. Gen. Laws ch. 211, 3 because he had an adequate alternative remedy.The district court issued a one-year harassment prevention order against Petitioner. Petitioner then filed a petition for extraordinary relief in the county court. The single justice denied the petition without holding a hearing, instructing Petitioner that his appeal from the order lay in the appeals court. The Supreme Judicial Court affirmed, holding that the single justice did not err or abuse her discretion in denying relief. View "A.F. v. D.F." on Justia Law

The Supreme Judicial Court held that Congress intended the Federal Volunteer Protection Act (VPA), 42 U.S.C. 14503(a), to provide qualified immunity from suit for officers in nonprofit organizations who receive no compensation, that the state charitable immunity statute, Mass. Gen. Laws ch. 231, 85W, may only expand the scope of that immunity and that Defendant, as a volunteer for a nonprofit organization, was entitled to interlocutory review of the denial of his motion for summary judgment.After a company was dissolved, Plaintiffs, former employees of Company, brought suit against Defendant, alleging that, as the company's president, he was among the employers who had violated the Wage Act, Mass. Gen. Laws ch. 149, 148, by failing to pay them the wages they were due. Defendant moved for summary judgment, arguing that even if he were the company's president, he served without compensation and was thus immune from suit under the VPA and section 85W. The superior court denied the motion. The Supreme Judicial Court affirmed, holding that there were genuine issues of material fact as to whether Defendant was placed outside of the immunity otherwise provided by section 85W. View "Lynch v. Crawford" on Justia Law

In this postconviction action arising from the misconduct of chemist Annie Dookhan at the William A. Hinton State Laboratory Institute the Supreme Judicial Court affirmed the order of the postconviction court denying Defendant postconviction relief, holding that Defendants who withdrew their guilty pleas after Dookhan's misconduct was discovered but before the Court's decision in Bridgman v. District Attorney for the Suffolk District, 471 Mass. 465 (2015), are entitled retroactively to the protection of the Bridgeman sentencing cap but only if they actually were convicted of more serious charges or received a more severe sentence than at their first plea.Defendant successfully moved to withdraw his guilty plea to trafficking cocaine on the ground that Dookhan's misconduct rendered his plea involuntary. Defendant then pleaded guilty to possession with intent to distribute. After Bridgeman was decided Defendant moved to withdraw his second guilty plea. The motion was denied. The Supreme Judicial Court affirmed, holding that where Defendant negotiated his second plea agreement in the shadow of the original charges but was not convicted of more severe charges and did not receive a harsher punishment there was no violation of the principles underlying the Bridgeman sentencing cap and thus no need for a third plea or trial in order to apply Bridgeman retroactively. View "Commonwealth v. Camacho" on Justia Law

The Supreme Judicial Court reversed the decision of the trial court dismissing this case alleging that a Massachusetts assisted living residence's (ALR) charge to new residents of an upfront "community fee" violated the security deposit statute, Mass. Gen. Laws ch. 186, 15B, holding that if an ALR charges upfront fees that are not used to fund distinct assisted living services, it does so in violation of section 15B.Plaintiff alleged that the community fee, which was intended to cover upfront administrative costs, move-in assistance, an initial service coordination plan, and a replacement reserve for building improvements, violated section 15B because it exceeded the upfront costs allowed by the statute. Defendant filed a motion to dismiss, arguing that ALRs are not subject to section 15B. The trial court granted the motion to dismiss. The Supreme Judicial Court remanded this case, holding (1) ALRs may institute upfront charges beyond those permitted by Mass. Gen. Laws ch. 186, 15B(1)(b) to the extent those charges correspondent to the distinct services enumerated in Mass. Gen. Laws ch. 19D, 13 or to other services specifically designed for ALRs; and (2) further factual development was required to determine whether the fee at issue here was permissibly charged and used for services distinct to ALRs. View "Ryan v. Mary Ann Morse Healthcare Corp." on Justia Law