Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendants’ convictions of murder in the first degree by reason of extreme atrocity or cruelty and felony-murder and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce the verdicts, holding that no prejudicial error occurred.The defendants in this case were Alexander Gallett and Michel St. Jean. The Supreme Judicial Court affirmed their convictions, holding (1) the motion judge did err in failing to suppress statements that Gallett made to police during his interrogation; (2) there was sufficient evidence to support St. Jean’s murder conviction; (3) St. Jean was not prejudiced by the admission of statements from Gallett’s redacted police interrogation; (4) the judge did not err in denying St. Jean’s requests for various jury instructions; (5) the trial judge did not improperly invoke juror sympathy; (6) there was no prejudicial error in limiting the cross-examination of certain witnesses; and (7) it was not reversible error for the judge to decline to give a humane practice jury instruction. View "Commonwealth v. Gallett" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree and declined to order a new trial or reduct the verdict under Mass. Gen. Laws ch. 278, 33E, holding that a new trial was not required in this case.Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Judicial Court affirmed the conviction, holding (1) the superior court did not abuse its discretion in denying Defendant’s motion for a new trial on the ground of undisclosed exculpatory evidence; (2) the superior court did not err in denying Defendant’s motion for a new trial; (3) the trial court did not err in denying Defendant’s motion to suppress; (4) certain evidence should not have been admitted, but there was no prejudice to Defendant; and (5) certain grand jury testimony should not have been admitted, but a new trial was not required on that basis. View "Commonwealth v. Ferreira" on Justia Law

The Supreme Judicial Court reversed the grant of summary judgment in favor of Defendants and the denial of Plaintiffs’ motion for summary judgment, holding that Plaintiffs, who worked for Defendants’ company that grew, harvested, packages, and distributed bean sprouts, were entitled to overtime pay for the hours they worked over forty each week under the overtime statute, Mass. Gen. Laws ch. 151, 1A.The superior court judge concluded Plaintiffs were not entitled to overtime wages because the work they performed fell under the agricultural exemption to the overtime statute, Mass. Gen. Laws ch. 151, 1A. The Supreme Judicial Court disagreed after reading the plain language of the exemption in Mass. Gen. Laws ch. 151, 1A(19) narrowly in include only the work of planting, raising, and harvesting crops, holding that Plaintiffs were not “engaged in agriculture and farming” within the meaning of the agricultural exemption and thus were entitled to overtime pay as provided by the overtime statute. View "Arias-Villano v. Chang & Sons Enterprises, Inc." on Justia Law

The Supreme Judicial court affirmed the district court judge’s order allowing Defendant’s motion to suppress narcotics seized from Defendant’s crotch area as a result of a strip search that took place in a cell at a police station, holding that police did not have probable cause to believe that Defendant had concealed narcotics somewhere on his person so as to justify conducting a strip search.Specifically, the Court held that, based on the facts of this case, the officers had, at best, a reasonable suspicion that Defendant could be concealing contraband in his crotch, but because there was no affirmative indication that Defendant was secreting contraband in his groin area, the police lacked probable cause to conduct a strip search of Defendant. View "Commonwealth v. Agogo" on Justia Law

The Supreme Court affirmed the trial court’s grant of Defendant’s motion to suppress in this case concerning the scope of the emergency aid exception and the exigent circumstances exception to the warrant requirement.Defendant filed a motion to suppress evidence seized pursuant to a warrant on the ground that the warrant was predicated on observations made during an unconstitutional warrantless search. The superior court allowed the motion. The appeals court reversed, concluding that the warrantless search was permissible under the emergency aid doctrine. The Supreme Court granted further appellate review and affirmed the order allowing the motion to suppress, holding (1) the warrantless search was not justified under the emergency aid exception; and (2) the search was not justified under the probable cause and exigent circumstances exception. View "Commonwealth v. Arias" on Justia Law

The Supreme Judicial Court held that the common-law doctrine of abatement ab initio, where a criminal conviction is vacated and the indictment is dismissed after the defendant dies while his direct appeal as of right challenging that conviction is in process, is outdated and that a new approach that is more consonant with the circumstances of contemporary life applies in the present case.In this case, the defendant may have committed suicide to prevent the application of the doctrine of abatement ab initio to benefit surviving family members, heirs, and other beneficiaries. The Supreme Judicial Court reversed the trial court’s order allowing Defendant’s motion to abate prosecution, dismissing Defendant’s notice of appeal, vacating his conviction, and dismissing the indictment and dismissing Defendant’s notice of appeal as moot. The Court held (1) when a defendant dies irrespective of cause while a direct appeal of right challenging his conviction is pending, the proper course is to dismiss the appeal as moot and note in the record that the conviction removed the defendant’s presumption of innocence but that the conviction was neither affirmed nor reversed on appeal because the defendant died; and (2) this approach, which otherwise applies only prospectively, should apply in the instant case. View "Commonwealth v. Hernandez" on Justia Law

In this divorce case, the Supreme Judicial Court affirmed the judgment of divorce nisi that awarded general term alimony to Wife and, among other things, divided the marital estate such that fifty-five percent of the overall assets were awarded to Husband and forty-five percent to Wife, holding that there was no error in the proceedings below.On appeal, Husband challenged the alimony award and the division of the marital estate. The Supreme Judicial Court affirmed, holding (1) the judge did not err in calculating the duration of the marriage for purposes of awarding alimony; and (2) the judge made no error in dividing the parties’ assets. View "Connor v. Benedict" on Justia Law

In this review of two decisions of the alcoholic beverages control commission (commission) that resulted in the issuance of penalties against Craft Beer Guild, LLC (Craft) and Rebel Restaurants, Inc. (Rebel), the Supreme Judicial Court affirmed in part and reversed in part the judgments of the superior courts affirming the commission’s penalties, holding that the commission properly determined that Craft violated both Mass. Gen. Laws ch. 138, 25A(a) and 204 Code Mass. Regs. 2.08 but that the terms of the regulation did not apply to Rebel’s conduct.After evidentiary hearings, the commission determined (1) Craft, a licensed wholesaler of craft beers, had paid monetary rebates in differing amounts on craft beer purchases to certain licensed retailers in violation of the statute; and (2) both Craft and Rebel violated the regulation, which prohibited a particular scheme of commercial bribery. The superior courts affirmed the commission’s penalties. The Supreme Judicial Court affirmed as to Craft but reversed as to Rebel, holding (1) Craft violated both the statute and the regulation, and the regulation remained valid; but (2) the terms of the regulation did not apply to Rebel’s conduct in accepting money derived from kickbacks paid by Craft. View "Craft Beer Guild, LLC v. Alcoholic Beverages Control Commission" on Justia Law

The Supreme Judicial Court reversed the trial judge’s denial of the Commonwealth’s renewed motion filed pursuant to Commonwealth v. Gelfgatt, 468 Mass. 512 (2014), and remanded for entry of an order compelling Defendant to enter a password into a cell phone seized from Defendant at the time of his arrest, holding that the motion judge abused his discretion in denying the Commonwealth’s motion.Defendant was charged with, among other things, trafficking a person for sexual servitude. The Commonwealth was granted a search warrant to search the cell phone found on Defendant, but the cell phone’s contents could only be accessed with the entry of a password. At issue was whether requiring Defendant to enter the cell phone’s password would violate his constitutional privilege against self-incrimination. A trial judge concluded that the Commonwealth failed to prove that Defendant’s knowledge of the password was a “foregone conclusion” under the Fifth Amendment to the United States Constitution and article 12 of the Massachusetts Declaration of Rights and denied the Commonwealth’s motion and renewed motion to compel Defendant to produce the password. The Supreme Judicial Court reversed, holding that Defendant’s knowledge of the password was a foregone conclusion and not subject to the protections of the Fifth Amendment and article 12. View "Commonwealth v. Jones" on Justia Law

The Supreme Judicial Court answered a question certified to it by the United States District Court for the District of Massachusetts concerning whether the six-year statute of repose set forth in Mass. Gen. Laws ch. 260, 2B operates to bar tort claims arising from diseases with extended latency periods where the defendants had knowing control of the injurious instrumentality at the time of exposure.The Supreme Judicial Court answered in the affirmative, concluding that section 2B completely eliminates all tort claims arising out of any deficiency or neglect in the design, planning, construction, or general administration of an improvement to real property after the established time period has run, even if the cause of action arises from a disease with an extended latency period, such as a disease associated with asbestos exposure, and even if a defendant had knowing control of the instrumentality of injury at the time of exposure. View "Stearns v. Metropolitan Life Insurance Co." on Justia Law