Justia Massachusetts Supreme Court Opinion Summaries

In this case concerning the legal relationship between the commercial custodian of three nondiscretionary IRAs and a named beneficiary of those accounts the Supreme Judicial Court reversed in part the decision of the superior court judge allowing UBS Financial Services, Inc.'s (UBS) motion for judgment on the pleadings as to all of Donna Aliberti's claims, holding that the facts alleged stated a claim that UBS's conduct violated Mass. Gen. Laws ch. 93A, 9 (chapter 93A).Following the death of the IRAs' original account holder this dispute arose between Aliberti, a named IRA beneficiary, and UBS, as IRA custodian. Aliberti asserted claims of breach of contract, breach of fiduciary duty, violation of chapter 93A, and intentional infliction of emotional distress. The superior court judge allowed UBS's motion for judgment on the pleadings as to all claims. The Supreme Judicial Court reversed in part, holding (1) there was no plausible claim for breach of fiduciary duty because the custodian of a nondiscretionary IRA does not generally owe a fiduciary duty to a named beneficiary of that IRA; and (2) the interactions between the commercial custodian of a nondiscretionary IRA and a named beneficiary of that IRA occur in a business context within the meaning of chapter 93A, and the alleged injurious conduct of UBS plausibly constituted a chapter 93A violation. View "UBS Financial Services, Inc. v. Aliberti" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of felony-murder and the denial of his motion for a new trial and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that there was no reason to order a new trial or to reduce the verdict of murder in the first degree.On appeal, Defendant argued that a new trial was necessary because his trial counsel provided ineffective assistance. The Supreme Judicial Court affirmed Defendant's convictions and the denial of his motion for a new trial and declined to reduce the verdict under Mass. Gen. Laws ch. 278, 33E, holding that Defendant's counsel did not provide ineffective assistance and that there was no reason to order a new trial or to reduce the verdict of murder in the first degree. View "Commonwealth v. Colon" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of possession of heroin with intent to distribute, reversed the denial of Defendant's motion for a new trial on the Mass. Gen. Laws ch. 94C, 32J (32J) charge, and vacated the conviction of a violation of section 32J, holding that counsel was ineffective in failing to challenge the sufficiency of the evidence regarding an essential element under section 32J.Defendant was convicted of possession of heroin with intent to distribute and with committing the crime within 100 feet of a public park, in violation of section 32J. The Supreme Judicial Court reversed in part, holding (1) the trial court did not err in denying Defendant's motion to suppress; (2) with respect to the "public park or playground" provision of section 32J, the intent to commit the underlying drug crime is sufficient, without additional proof of knowledge of park or playground boundaries required; (3) whether an area of land is a public park under section 32J is a question of fact properly left to the fact-finder; and (4) trial counsel was ineffective for failing to raise the variance between the park named in the indictment and the evidence presented at trial. View "Commonwealth v. Matta" on Justia Law

The Supreme Judicial Court dismissed the Commonwealth's appeal from the trial court's allowance of Defendant's motion filed under Mass. R. Crim. P. 25(a), holding that the trial judge erred in reserving decision on Defendant's Rule 25(a) motion and that the error violated Defendant's right to due process and permeated the remainder of the trial.Defendant was charged with murder in the first degree. At the close of the Commonwealth's case Defendant moved for a required finding of not guilty pursuant to Rule 25(a). The judge reserved decision and submitted the case to the jury. The jury found Defendant guilty of murder in the second degree. Defendant subsequently renewed his motion under Rule 25(a). The judge allowed the motion, nunc pro tunc, to the close of the Commonwealth's case. The Commonwealth petitioned for relief under Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court denied relief, holding (1) in allowing the motion for a required finding nunc pro tunc after the jury returned their verdict the judge deprived the Commonwealth of its right to appeal from a postverdict acquittal; but (2) because the initial error in reserving decision on the motion implicated Defendant's constitutional rights and infected the remainder of the trial, the Commonwealth could not appeal. View "Commonwealth v. Yasin" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the Court denying Appellant's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that principles of double jeopardy did not bar Appellant's retrial, and therefore, the single justice neither erred nor abused its discretion in denying relief.Appellant was indicted for murder in the first degree and arson in a dwelling. After the jury deadlocked, Appellant's jury trial ended in a mistrial. Appellant subsequently moved to dismiss the indictments, arguing that the Commonwealth failed to present sufficient evidence at his first trial to warrant a conviction with respect to either charge, and therefore, principles of double jeopardy barred his retrial. The Supreme Judicial Court affirmed, holding that the evidence was sufficient for a rational jury to convict Appellant of murder in the first degree, as well as arson in a dwelling. View "Coggins v. Commonwealth" on Justia Law

The Supreme Court vacated the order of the superior court judge allowing Defendant's motion to suppress all evidence related to an illegal seizure on the ground that the stop of his motor vehicle was not reasonable, holding that the police officer's stop of Defendant's motor vehicle for failing to drive entirely within a marked traffic lane was reasonable and, therefore, constitutional.Defendant was charged with a marked lanes violation in accordance with Mass. Gen. Laws. ch. 89, 4A and operating a motor vehicle while under the influence of intoxicating liquor. The judge allowed Defendant's motion to suppress, ruling that Defendant had not violated section 4A, and therefore, the stop of his motor vehicle was not reasonable. The Supreme Court vacated the judge's order, holding that Defendant violated section 4A when he crossed the right-side fog line one time for two or three seconds, and therefore, the ensuing traffic stop was reasonable. View "Commonwealth v. Larose" on Justia Law

The Supreme Judicial Court affirmed the decision of the Commonwealth Employment Relations Board upholding a certain provision in a collective bargaining agreement between the Board of Higher Education (BHE) and the Massachusetts State College Association, holding that the provision was a proper subject of collective bargaining.The provision at issue placed a cap on the percentage of courses taught by part-time faculty at the Commonwealth's State colleges. On appeal, the BHE argued that although it bargained for this provision, the provision was not enforceable because it impermissibly intruded on the nondelegable managerial prerogatives of the State college boards of trustees. The Supreme Judicial Court affirmed, holding that the provision was valid and enforceable. View "Board of Higher Education v. Commonwealth Employment Relations Board" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of deliberate premeditation and the denial of his motion for a new trial, holding that Defendant was not entitled to relief on any of his allegations of error and that there was no abuse of discretion in the denial of Defendant's motion for a new trial.Specifically, the Court held (1) the trial court did not err in allowing certain statements to be introduced at trial; (2) the trial judge did not err in declining to instruct the jury on involuntary manslaughter; (3) there was not a substantial likelihood of a miscarriage of justice on the basis of counsel's closing argument and no abuse of discretion in the denial of Defendant's motion for a new trial; and (4) there is not reason to grant a new trial or to reduce the verdict pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Moseley" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of involuntary manslaughter but affirmed Defendant's conviction of distribution of heroin, holding that the Commonwealth did not introduce evidence showing that Defendant knew or should have known that his conduct created a high degree of likelihood of substantial harm.Defendant had provided a college student with the heroin that caused the student's death. Defendant was convicted of involuntary manslaughter and distribution of heroin. Defendant appealed, arguing, inter alia, that the judge erred in denying his request to instruct the jury on the lesser included offense of possession of heroin for personal use because the student asked Defendant to purchase heroin for him and Defendant did not profit from the sale. The Supreme Judicial Court affirmed in part and vacated in part, holding (1) under the circumstances of this case, the judge did not err in denying Defendant's request for a lesser included jury instruction on simple possession; but (2) there was insufficient evidence for a reasonable jury to conclude that Defendant's conduct created a high degree of likelihood that the student would suffer substantial harm for his use of the heroin. View "Commonwealth v. Carrillo" on Justia Law

The Supreme Judicial Court affirmed the orders denying a motor vehicle insurer's motions to stay trial in a wrongful death action until the question of coverage had been determined in a declaratory judgment action but and denying the insurer's Mass. R. Civ. P. 67 motion and vacated the wrongful death judgment, holding that the matter must be remanded for a reasonableness hearing.The Supreme Judicial Court addressed issues that arose where Insurer recognized its duty to defend Insureds in a wrongful death action but did so under a reservation of rights and then brought a separate action seeking a declaratory judgment that it owed no duty to indemnify Insureds for damages arising from the wrongful death action. The parties subsequently settled the wrongful death action. The plaintiff agreed to release the defendants from liability and seek damages only from Insurer. Insurer moved to deposit with the court the policy limit and postjudgment interest under Rule 67. The Supreme Judicial Court held (1) the judge properly denied Insurer's motions to stay; (2) the judge properly denied Insurer's motion to deposit the funds; and (3) where the settlements were executed with no determination of reasonable, the case must be remanded for a hearing on the reasonableness of the settlement/assignment agreements. View "Commerce Insurance Co. v. Szafarowicz" on Justia Law