Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court vacated and set aside a superior court judgment affirming a Sex Offender Registry Board (SORB) decision to classify John Doe as a level two sex offender, holding that there was not substantial evidence to support the hearing examiner's decision to classify Doe as a level two sex offender by clear and convincing evidence.SORB classified Doe as a level two sex offender after Doe was convicted of two counts of open and gross lewdness. The superior court affirmed. The Supreme Judicial Court vacated the judgment, holding (1) SORB had jurisdiction to classify Doe as a sex offender; (2) in order classify an individual as a level two sex offender, the hearing examiner is required to make three explicit determinations by clear and convincing evidence; and (3) in light of this three-prong test, the hearing examiner did not support her decision to classify Doe as a level two sex offender by clear and convincing evidence. View "Doe v. Sex Offender Registry Board" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying Petitioner's "Verified Complaint for Declaratory and Injunctive Relief" without a hearing, holding that the single justice did not err in denying relief.Specifically, the Court held that Petitioner's request for declaratory and inductive relief was a mere recasting of the same types of claims Petitioner raised in his previous postconviction filings, and even if his claims were new, his avenue for seeking relief was in the superior court in the first instance. Therefore, the single justice did not err or abuse her discretion in denying relief. View "Vinnie v. Superintendent, Massachusetts Correctional Institution, Norfolk" 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, holding that the single justice did not err or abuse his discretion in denying relief.While Petitioner was incarcerated in Indiana for unrelated offenses, he filed a petition for a speedy disposition of Massachusetts charges underlying this action pursuant to the Interstate Agreement on Detainers (IAD). Petitioner then filed a motion to dismiss, arguing that the Commonwealth had failed to bring him to trial within the time frame required by the IAD. A district court judge allowed the motion. Meanwhile, Petitioner had been indicted on the same charges. Petitioner moved to dismiss the charges on jurisdictional grounds. The superior court judge denied the motion. Petitioner then filed his Mass. Gen. Laws ch. 211, 3 petition arguing that in denying the jurisdictional motion, the superior court judge had revoked the district court judge's dismissal of the complaint. The superior court denied the IAD motion before the single justice acted on the Mass. Gen. Laws ch. 211, 3 petition. Thereafter, the single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice did not err in denying relief. View "Ghebrehiwet v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice denying Petitioner's petition seeking relief in the nature of mandamus and pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief.Petitioner commenced an action in the superior court against Respondent. After the superior court granted Respondent's motion to stay discovery, Petitioner filed a motion for final judgment on the basis that Respondent had failed to respond to the discovery requests. The motion was denied. Petitioner then filed a complaint seeking relief in the nature of mandamus and pursuant to Mass. Gen. Laws ch. 211, 3 asking the Court to order the superior court clerk to enter judgment in Petitioner's favor. The single justice denied the petition without a hearing. The Supreme Judicial Court affirmed, holding that this was not a situation where extraordinary relief from this Court was required. View "Navom v. Clerk of the Superior Court in Middlesex County" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying Petitioner's document entitled "Abuse of Authority: Judicial Misconduct" arising from the alleged misconduct of an assistant clerk-magistrate of the Boston Municipal Court who presided over a small claims proceeding to which Petitioner was a party, holding that the single justice properly denied relief under Mass. Gen. Laws ch. 211, 3.The single justice treated Petitioner's filings as a petition for extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3 and later denied a motion for reconsideration. The Supreme Judicial Court affirmed and took the opportunity of this case to clarify the process for lodging complaints against clerks and assistant clerks pursuant to S.J.C. Rule 3:13, as appearing in 471 Mass. 1301, holding that Petitioner lacked standing to bring a private action in court to obtain discipline of a clerk. View "White v. Chief Justice of Boston Municipal Court" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of simple assault and threatening to commit a crime, holding that the criminal docket of one of Defendant's friends was improperly admitted as evidence against Defendant and that the jury was permitted to return a guilty verdict without reaching a unanimous consensus as to which facts supported that charge.Defendant's convictions stemmed from a violent encounter among four men. During trial, the judge allowed into evidence a copy of the certified criminal docket in Defendant's friend's Charles's case, which reflected that Charles had pleaded guilty to assault by means of a dangerous weapon for an incident charged on the same day as the incident in which Defendant was charged. On appeal, Defendant argued that the certified docket sheet from Charles's case should not have been admitted and that the jury should have been given a specific unanimity instruction with respect to the offense of threatening to commit a crime. The Supreme Judicial Court agreed, holding that both claims constituted reversible error. The Court vacated the convictions and remanded the matter for a new trial. View "Commonwealth v. Palermo" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of deliberate premeditation and felony-murder and declined to exercise its power under Mass. Gen. Laws ch. 278, 33E to reduce the conviction to murder in the second degree, holding that no reversible error occurred in the proceedings below.After he was convicted Defendant filed a motion for a new trial, arguing that his trial counsel provided constitutionally ineffective assistance particularly in regards to DNA evidence presented by the Commonwealth. The trial court denied the motion for a new trial and a subsequent motion for reconsideration. Defendant appealed, raising the same ineffective assistance of counsel claims and, for the first time, a challenge that certain evidence should have been excluded as hearsay. The Supreme Judicial Court affirmed, holding (1) the challenged testimony was properly admitted against Defendant as a statement by a party opponent; and (2) none of Defendant's claims of error regarding defense counsel's treatment of the DNA evidence required a new trial. View "Commonwealth v. Barnett" on Justia Law

The Supreme Judicial Court vacated the jury's verdict in favor of Defendant in this medical malpractice action for injuries arising after surgery, holding that while the trial judge did not err under current law of evidence in excluding certain out-of-court statements, under new grounds for finding unavailability adopted in this opinion, the testimony's absence was grounds for a new trial.The out-of-court statements at issue in this case were made by a medical student who participated in the surgery. The trial judge determined that the statements could not be entered in evidence as statements of a party opponent made by an agent nor as statements against interest by an unavailable declarant. The Supreme Court remanded the case for a new trial after taking the opportunity to adopt as a matter of common law proposed Mass. R. Evid. 804(a)(3), which would allow a declarant in a civil case to be deemed unavailable if he or she testifies to a lack of memory about the subject matter in question. The Court held that if the trial judge had had the benefit of the grounds for finding unavailability adopted today, it would have been an abuse of discretion not to have admitted the statements as statements against interest by an unavailable witness. View "Hedberg v. Wakamatsu" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E but reversed the order denying Defendant's motion for third-party discovery and vacated the orders denying Defendant's motions for a new trial, holding that Defendant's motion for third-party discovery should have been allowed and that denying Defendant's motions for a new trial without first conducting an evidentiary hearing was error.The Supreme Court remanded this case to the superior court to allow Defendant to conduct the requested third-party discovery of e-mail service providers to determine whether additional e-mail messages between the victim and a third-party culprit existed. The Court noted that Defendant may amend his second motion for a new trial to include any information obtained as a result of the discovery requests. View "Commonwealth v. Holbrook" on Justia Law

The Supreme Judicial Court vacated the superior court's grant of summary judgment in favor of Defendants, the former accounts of Plaintiff, the Chelsea Housing Authority, on the ground that Plaintiff's claim of negligence against Defendants was barred by the common-law doctrine of in pari delicto, holding that, by enacting Mass. Gen. Laws ch. 112, 87A 3/4, the Legislature intended to preempt the doctrine of in pari delicto in cases where an accountant is sued for failing to detect fraud committed by a client.In this action, Plaintiff sought to recover the losses incurred from the accountants' alleged negligent failure to detect the fraudulent conduct of its former executive director, its former finance director, and others. A superior court judge concluded that Plaintiff's claim was barred by the doctrine of in pari delicto without addressing the applicability of section 87A 3/4. The Supreme Judicial Court vacated the summary judgment, holding that the Legislature has preempted the common-law doctrine of in pari delicto doctrine as it applies to the negligent conduct of accountants and auditors in failing to detect fraud. View "Chelsea Housing Authority v. McLaughlin" on Justia Law