Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the superior court's order granting Defendant's motion to dismiss the cocaine and cash seized during a warrantless search of his residence, holding that Defendant's consent to a search of his residence did not purge the seizure from the taint of an illegal cell site location information (CSLI) search, where the consent was obtained through the use of information obtained from that search.The superior court ruled that the cash and cocaine must be suppressed because they were the fruits of unlawful police tracking of a cellular telephone through which the police obtained CLSI without a search warrant based on probable cause. The Supreme Judicial Court affirmed, holding (1) by monitoring the cell phone's CSLI, the police effectively monitored the movement of a vehicle in which Defendant was a passenger, thus giving Defendant standing to challenge the Commonwealth's warrantless CSLI search; (2) the seizure of the cocaine and cash was the direct result of information obtained from the illegal CSLI search; and (3) the Commonwealth failed to meet its burden of proving that the seizure was sufficiently attenuated from the illegal search such that it should not be deemed a forbidden fruit of the poisonous tree. View "Commonwealth v. Fredericq" on Justia Law

The Supreme Judicial Court reversed the motion judge's allowance of Defendant's motion to suppress, holding that police action causing an individual's cell phone to reveal its real-time location constitutes a search in the constitutional sense under article 14 of the Massachusetts Declaration of Rights, but, in this case, the warrantless search was supported by probable cause and was reasonable under the exigent circumstances exception to the search warrant requirement.After the police identified Defendant as the suspect in a murder case, the police contacted Defendant's cellular service provider to request the real-time location of Defendant's cell phone. They did so without a warrant. The service provider "pinged" Defendant's cell phone, which caused the cell phone to transmit its real-time GPS coordinates to the service provider. The GPS coordinates were relayed to the police, and the police were able to use that information to locate Defendant. Defendant moved to suppress the evidence as the fruit of an unlawful search. The motion judge allowed the suppression motion. The Supreme Judicial Court reversed, holding that the motion judge erred in concluding that the warrantless ping of Defendant's cell phone was not justified by exigent circumstances. View "Commonwealth v. Almonor" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying Appellant's complaint for relief in the nature of mandamus, holding that the single justice neither erred nor abused her discretion by denying relief.Appellant was convicted of first in the first degree. Appellant later requested from the Office of the Chief Medical Examiner (OCME) twenty-seven categories of documents concerning the medical examiner who performed an autopsy on the body of the victim. The OCME denied the request. Appellant appealed to the supervisor of records. The supervisor instructed the OCME to redact the records where necessary, provide them to Appellant, and to the extent the OCME claimed the records were exempt from disclosure, provide a response to support the exemption claim. When the OCME did not do so in a timely manner, Snell filed his complaint. The single justice denied relief. The Supreme Judicial Court affirmed, holding that where Appellant made no showing that the OCME had a clear cut duty to produce the documents or that the OCME was refusing to comply with the supervisor's instructions, Appellant failed to show that he was entitled to relief in the nature of mandamus. View "Snell v. Office of the Chief Medical Examiner" on Justia Law

In this criminal case, the Supreme Judicial Court reversed the judgment of a single justice of the court denying the Commonwealth's petition for relief pursuant to Mass. Gen. Laws ch. 211, 3 and remanded the case for entry of a judgment vacating a superior court judge's order allowing Defendant's motion in limine to exclude prior recorded testimony, holding that the judge erred in precluding the prior testimony.Here, the Commonwealth had no alternative avenue to obtain review of the judge's allowance of Defendant's motion in limine. At issue, then, was whether the Commonwealth's claim was "exceptional" for purposes of Mass. Gen. Laws ch. 3. The Supreme Judicial Court held (1) the single justice abused his discretion in determining that there were no exceptional circumstances in this case; and (2) the evidence was admissible because it satisfied the hearsay exception for prior recorded testimony and the constitutional restraints on that exception. View "Commonwealth v. Fontanez" on Justia Law

In this case brought under the Wage Act, Mass. Gen. Laws ch. 149, 150, the Supreme Judicial Court reversed the denial of Plaintiff's motion for class certification, holding that Mass. R. Civ. P. 23, as amended, provides the correct standard for determining class certification in a claim under the wage laws and that Plaintiff met his burden of demonstrating numerosity under that rule.Plaintiff alleged on behalf of himself and a putative class of similarly situated employees that Defendant had a practice of violating the "reporting pay" or "three hour" requirement of 454 Code Mass. Regs. 27.04(1). At issue was whether either the Wage Act or the minimum fair wage law, Mass. Gen. Laws ch. 151, 20, specify a different standard for class certification from that set forth in Rule 23 and whether the numerosity requirement was satisfied in this case. The motion judge denied Plaintiff's motion for class certification, concluding that the class was insufficiently numerous to satisfy the certification requirements of Rule 23. The Supreme Judicial Court reversed and remanded for further proceedings, holding that the motion judge correctly used the Rule 23 factors to analyze Plaintiff's claim but that the judge abused his discretion in denying class certification. View "Gammella v. P.F. Chang's China Bistro, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Appellant's complaint for relief in the nature of mandamus or, in the alternative, for relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion in denying the complaint.Appellant commenced a qui tam action. The case was dismissed, and the appeals court affirmed. Appellant filed a petition for rehearing in the appeals court. A replacement judgment took part in the decision denying the petition for rehearing. Appellant's ensuing motion for recusal of the replacement judge was denied. Appellant then sought relief in the nature of mandamus to compel the replacement judge to demonstrate the basis for his decision not to recuse himself, to order the recusal, and to compel the appeals court to reconsider his petition for rehearing. The Supreme Judicial Court held that the single justice correctly denied relief because Appellant's issues were not the type of action that could be compelled by a complaint for mandamus and that Appellant failed to demonstrate the absence or inadequacy of remedies alternative to Mass. Gen. Laws ch. 211, 3. View "Chawla v. Appeals Court" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition for extraordinary relief from an order of the Housing Court denying Petitioner's motion to remove a receiver appointed with respect to real property owned by East Fourth Street, LLC, holding that the single justice did not err or abuse her discretion in denying the petition.In denying Petitioner's petition, the single justice held that Petitioner failed to demonstrate that the extraordinary relief he sought was appropriate in this case. The Supreme Judicial Court affirmed, holding (1) the Housing Court correctly determined that Petitioner, who is not an attorney, cannot present arguments on behalf of his limited liability company, which was the owner of the property that had been placed into receivership; (2) Petitioner's ownership interest in the LLC did not give him standing to raise the claims of the company, pro se, in his individual capacity; and (3) Mass. Gen. Laws ch. 211, 3 is generally not an appropriate avenue to challenge an order appointing a receiver. View "Dickey v. Inspectional Services Department of Boston" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, in which Petitioner challenged summary process proceedings in the Worcester Division of the Housing Court Department, now part of the Central Division (Housing Court), holding that the single justice did not err or abuse her discretion in denying relief.Petitioner was a self-represented litigant engaged in a summary process eviction action after her home was purchased at a foreclosure sale. On appeal, Petitioner argued that the Housing Court judge erred in denying her request for a reasonable accommodation, violated a Federal Bankruptcy Court automatic stay order, and violated her right to due process. The Supreme Judicial Court held that Petitioner was not entitled to relief under Mass. Gen. Laws ch. 211, 3 because she did not meet her burden of demonstrating the absence or inadequacy of other remedies. View "Evans v. Federal Home Loan Mortgage Corp." on Justia Law

In this appeal brought by Defendant challenging his conviction of murder in the first degree on a theory of felony-murder the Supreme Judicial Court vacated Defendant's underlying felony conviction of armed robbery as duplicative, affirmed Defendant's remaining convictions, and affirmed the denial of Defendant's motion for a new trial, holding that a conviction on an underlying felony is duplicative of a felony-murder conviction, and the underlying felony must be vacated.The Supreme Judicial Court further declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce or set aside the verdict of murder in the first degree, holding (1) Defendant failed to establish that his trial counsel provided ineffective assistance; (2) the Commonwealth did not engage in impermissible burden shifting by suggestion that Defendant had a duty to obtain or preserve evidence during a police interview; and (3) where Defendant was convicted of felony-murder in the first degree with the predicate offenses of both armed robbery and armed home invasion, a conviction on all three counts violated double jeopardy protections. View "Commonwealth v. Simon" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying Petitioners relief under Mass. Gen. Laws ch. 211, 3, in which Petitioners challenged summary process proceedings in the Worcester Division of the Housing Court Department, now part of the Central Division (Housing Court), holding that the single justice did not abuse his discretion or otherwise err in denying Petitioners' petition.Although most Petitioners in this case were also petitioners in Adjartey v. Central Division of Housing Court Department, 481 Mass. __ (2019), also decided today, Petitioners, who were involved in eviction actions stemming from the foreclosure of their homes, raised specific complaints in this case that were not addressed in the Adjartey case. Here, Petitioners claimed that the Housing Court violated their substantive and procedural due process rights, as well as other constitutional rights. The Supreme Judicial Court affirmed the single justice's denial of relief, holding that Petitioners failed to meet their burden to demonstrate the absence or inadequacy of other remedies, as is required for purposes of Mass. Gen. Laws ch. 211, 3. View "Hilton v. Central Division of the Housing Court Department" on Justia Law