Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the single justice's order denying Petitioners' request for relief under Mass. Gen. Laws ch. 211, 3 challenging 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.Petitioners in this case were self-representated litigants navigating eviction cases in the Housing Court. Each petitioner claimed that he or she was improperly denied a fee waiver for audio recordings of his or trial court proceedings, was unable to access audio recordings in time to prepare for a Housing Court or appellate court proceeding, or was required to reveal his or her indigency in open court while requesting audio recordings. The single justice dismissed Petitioners' Mass. Gen. Laws ch. 211, 3 petition without a hearing. The Supreme Judicial Court affirmed but took the opportunity to clarify and provide guidance regarding several issues raised by the facts alleged in this case, acknowledging the many challenges that exist for self-represented litigants facing eviction. View "Adjartey v. Central Division of Housing Court Department" on Justia Law

The Supreme Judicial Court vacated in part and affirmed in part the decision of the Commonwealth Employment Relations Board upholding the Department of Labor Relations' (DLR) dismissal of Employees' challenges under the First Amendment to the exclusive representation and the mandatory agency fee provisions of the collective bargaining statute, Mass. Gen. Laws ch. 150E, holding that Employees' constitutional challenge to the agency fee provision was moot and that the First Amendment challenge to the exclusive representation provisions of the statute was foreclosed by Supreme Court precedent.While this case was on appeal, the United States Supreme Court held, in Janus v. American Federation of State, County & Municipal Employees, Council 31, 138 S. Ct. 2448 (2018) that all State agency fee laws violate the First Amendment by compelling nonmembers of public sector unions to support their unions' speech. The Supreme Judicial Court held (1) because the unions voluntarily stopped collecting agency fees to comply with Janus, Employees' agency fee provision challenge was moot; and (2) because the Supreme Court has deemed exclusive representation to be constitutional, Employees' challenge to the exclusive representation provisions of the statute were without merit. View "Branch v. Commonwealth Employment Relations Board" on Justia Law

The Supreme Judicial Court reversed the motion court's order denying Defendant's motion filed under Mass. Gen. Laws ch. 278A asserting his factual innocence and requesting forensic testing of certain evidence, holding that Defendant's motion satisfied the threshold burden of Mass. Gen. Laws ch. 278A, 3(b)(4).Defendant was convicted of home invasion, armed assault in a dwelling, rape, and assault and battery. Defendant later filed a motion pursuant to chapter 278A seeking postconviction forensic and scientific testing of evidence and biological material to support a motion for a new trial. The motion judge denied the motion, concluding that Defendant's claim that no crime occurred in this case was barred from chapter 278A relief because it did not put identity at issue. The Supreme Judicial Court reversed on the basis of its opinion today in Commonwealth v. Williams, 481 Mass. __ (2019), holding that Defendant's motion satisfied the threshold burden of Mass. Gen. Laws ch. 278A, 3(b)(4) because, as stated in Williams, "a defendant who asserts that the requested testing has the potential to result in evidence that is material to his or her identity as the perpetrator of the crime because no crime in fact occurred satisfies the [section] 3(b)(4) requirement." View "Commonwealth v. Putnam" on Justia Law

The Supreme Judicial Court reversed the order of the motion judge denying Defendant's Mass. Gen. Laws ch. 278A, 3 motion, holding that Defendant, who claimed that no crime occurred, made a prima facie case for a chapter 278A request.Defendant pleaded guilty to manslaughter and unlawful possession of a firearm and ammunition. Defendant later filed this motion under chapter 278A alleging that he acted in self-defense. Defendant sought forensic testing of evidence, claiming that the testing would show that the weapon belonged to the victim and that Defendant shot the victim in self-defense. The motion judge denied Defendant's motion. The Supreme Judicial Court reversed, holding that Defendant satisfied the requirement of Mass. Gen. Laws ch. 278A, 3(b)(4) by properly asserting his factual innocence and asserting that the requested testing had the potential to result in evidence that was material to Defendant's identity as the perpetrator of the crime in the underlying case. View "Commonwealth v. Williams" on Justia Law

The Supreme Judicial Court affirmed the decision of the trial judge to grant Defendant's motion to revise and revoke his sentence to match that of his coventurer, holding that a judge may allow a defendant's motion to revise and revoke a sentence under Mass. R. Crim. P. 29(a)(2) based upon the disparity between the defendant's sentence and a coventurer's sentence subsequently imposed by a different judge.Defendant was convicted of armed robbery and other charges. Defendant received a prison sentence fo from six to eight years on the robbery count. After a separate trial before a different judge, Defendant's coventurer received a prison term of from five to seven years for armed robbery. Defendant filed a motion to revoke and revoke based on the disparity between those two sentences. The judge reduced Defendant's sentence to match the sentence of the coventurer. The Appeals Court reversed, concluding that the judge's decision was improperly based on an event that occurred after Defendant had already been sentenced. The Supreme Judicial Court granted further review and held that, under the circumstances of this case, the judge did not abuse her discretion in considering the coventurer's later-imposed sentence where the coventurer was more culpable and received a more lenient sentence. View "Commonwealth v. Tejeda" on Justia Law

In this case involving a claimant seeking to enforce a target lien bond by commencing a civil action pursuant to the mechanic's lien statute, Mass. Gen. Laws ch. 254, 14, the Supreme Judicial Court vacated the superior court's order allowing Defendant Arch Insurance Company's (Arch) summary judgment, holding that the lien statute contains no requirement that the claimant record an attested copy of the complaint in the registry of deeds.City Electric Supply Company (CES) supplied electrical materials for a construction project in Brookline and perfected a mechanic's lien on the Brookline property. Later, general contractor Tocci Building Corporation issued and recorded a target lien bond in the amount of the mechanic's lien CES had created. The target lien bond listed Arch as surety. CES then filed an action against Arch seeking to enforce the target lien bond. A superior court judge granted summary judgment for Arch, concluding that suit on a lien bond requires an attested copy of the complaint to be recorded. The Supreme Judicial Court reversed and remanded the case, holding that a party seeking to enforce a target lien bond need not record a copy of a complaint in the registry of deeds as a condition precedent to enforcing the bond. View "City Electric Supply Co. v. Arch Insurance Co." on Justia Law

The Supreme Judicial Court affirmed the district court's denial of Defendant's motion to dismiss the complaint charging unlawful possession of a firearm on constitutional grounds and denied Defendant's request for a new trial on the grounds of alleged errors in the jury instructions and asserted improper questioning of a witness by the prosecutor, holding that there was not a substantial risk of a miscarriage of justice in this case.Defendant, a firearm owner licensed to carry firearms in New Hampshire, did not obtain a Massachusetts firearm license within the statutory time period for new residents. Defendant was convicted of firearm-related offenses. The Supreme Judicial Court affirmed, holding (1) the trial judge did not err in denying Defendant's motion to dismiss where there was no doubt that Defendant lacked a Massachusetts firearm license and that Defendant could have applied for such a license within the statutory period filling his arrival in the Commonwealth; (2) Defendant suffered no prejudice from the jury instructions he challenged on appeal; and (3) the question the prosecutor posed to the witness in this case did not create a substantial risk of a miscarriage of justice. View "Commonwealth v. Harris" on Justia Law

The Supreme Judicial Court affirmed the single justice's judgment denying Defendant's petition for relief challenging the denial of his bail requests, holding that the bail judge did not abuse his discretion or commit an error of law in denying Defendant's bail request.After Defendant's indictment and arraignment for murder in the first degree and related charges, a superior court judge ordered Defendant to be held without right to bail. Defendant's ensuing requests for admission to bail were denied. Defendant petitioned for relief under Mass. Gen. Laws ch. 211, 3, which a single justice of the county court denied. The Supreme Judicial Court affirmed after reviewing and applying the legal standards for bail decisions, holding (1) a defendant charged with murder in the first degree has no right to bail but may be admitted to bail in the discretion of the judge; and (2) the bail judge did not make a clear error of judgment in weighing the factors relevant to his decision such that the decision fell outside the range of reasonable alternatives. View "Vasquez v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed the motion judge's denial of Defendant's motion to suppress and Defendant's convictions of breaking and entering and larceny, holding that the Commonwealth's act of accessing and reviewing historical GPS location data recorded from a GPS monitoring device that was attached to Defendant as a condition of his probation was not a search in the constitutional sense.Specifically, the Court held (1) although the original imposition of GPS monitoring as a condition of Defendant's probation was a search, it was reasonable in light of Defendant's criminal history and apparent willingness to recidivate while on probation; (2) once the GPS device was attached to Defendant, he did not possess a reasonable expectation of privacy in data targeted by police to determine his whereabouts; and (3) the evidence was sufficient to support Defendant's convictions of breaking and entering in the nighttime and larceny over $250. View "Commonwealth v. Johnson" on Justia Law

In this criminal case, the Supreme Judicial Court held that, as applied to Defendant, GPS monitoring as a condition of Defendant's probation was an unconstitutional search under article 14 of the Massachusetts Declaration of Rights.Defendant was convicted of possession and distribution of child pornography. The terms of Mass. Gen. Laws ch. 265, 47 requires judges to impose GPS monitoring as a condition of probation for individuals convicted of most sex offenses. In accordance with the statute, the sentencing judge imposed GPS monitoring as a condition of Defendant's probation. Defendant appealed, arguing that, as applied to him, the condition of mandatory GPS monitoring constituted an unconstitutional unreasonable search. The Supreme Judicial Court agreed, holding (1) Mass. Gen. Laws ch. 265, 47 is over inclusive in that GPS monitoring will not necessarily constitute a reasonable search for all individuals convicted of a qualifying sex offense; (2) to comport with article 14, prior to imposing GPS monitoring on a defendant, a judge is required to conduct a balancing test weighing the Commonwealth's need to impose GPS monitoring against the defendant's privacy invasion arising by the monitoring; and (3) in the instant case, the Commonwealth's particularized reasons for imposing GPS monitoring on Defendant did not outweigh the privacy invasion that GPS monitoring entails. View "Commonwealth v. Feliz" on Justia Law