Justia Massachusetts Supreme Court Opinion Summaries

In this, the second of two cases decided today involving Wayne Chapman, the Supreme Judicial Court affirmed the judgment of a single justice of the Court denying Petitioners' petition for relief under Mass. Gen. Laws ch. 211, 3, in which they sought to enjoin Chapman's release from the Massachusetts Treatment Center, holding that Petitioners were not entitled to they relief they sought.After two qualified examiners opined that Chapman was no longer sexually dangerous Petitioners, individuals who were enrolled in the victim notification registry for Chapman, applied for emergency relief in the county court seeking to enjoin Chapman's release. The single justice denied the petition. The Supreme Judicial Court affirmed, holding (1) Petitioners did not have standing to assert the majority of the claims they made; and (2) even if Petitioners' claim that they were not given proper advance of Chapman's imminent discharge, the claim would not entitle Petitioners to an order enjoining Chapman's release. View "In re Chapman" on Justia Law

The Supreme Judicial Court affirmed the superior court judge's order allowing Wayne Chapman's petition for release from civil commitment as a sexually dangerous person, holding that Defendant was not required to remain civilly committed after neither of two qualified examiners had concluded that Defendant was no longer sexually dangerous.When Chapman had approximately one month remaining until his anticipated release from prison the Commonwealth filed a petition to commit Chapman as a sexually dangerous person beyond the term of his criminal sentence under the current version of Mass. Gen. Laws ch. 123A. After trial, Chapman was found to be sexually dangerous and committed to the treatment center for an indeterminate period. Chapman then filed petitions for discharge from civil commitment under chapter 123A, section 9, including the one at issue here. Two qualified examiners offered the opinion that Chapman was no longer sexually dangerous. Chapman then moved for a discharge. The superior court judge, relying on Johnstone, petitioner, 453 Mass. 544, 553 (2009), allowed Chapman's motion. The Supreme Judicial Court affirmed, holding (1) Johnstone was correctly decided, and the principle of stare decisis counsels in favor of adherence to this settled precedent; and (2) where both qualified examiners concluded that Defendant was not sexually dangerous, discharge was appropriate. View "Chapman, petitioner" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree on the theories of felony-murder and extreme atrocity or cruelty and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that there was no reason to grant a new trial or to either reduce or set aside the verdict.Specifically, the Court held (1) Defendant failed to show actual juror prejudice by way of pretrial publicity; (2) the judge did not abuse his discretion in admitting fingerprint evidence because the evidence was properly authenticated; (3) trial counsel did not provide ineffective assistance; and (4) the prosecutor's statements during closing argument did not amount to reversible error. View "Commonwealth v. Mack" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of armed robbery and murder in the first degree and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or to order a new trial, holding that there was no basis upon which to order a new trial or to reduce the degree of guilt.Specifically, the Court held (1) the trial judge did not abuse its discretion in allowing the jurors' request for a magnifying glass during deliberation; (2) the jury instruction on circumstantial evidence and inferences did not unconstitutionally diminish the Commonwealth's burden of proof or violate Defendant's due process rights; and (3) the trial court did not err in permitting Defendant's coworker to testify to Defendant's statement that, if he were to break into the neighbors' house, he would kill the neighbors. View "Commonwealth v. Silva" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty and declined to exercise its extraordinary authority to afford relief under Mass. Gen. Laws ch. 278, 33E, holding that there was no error in the proceedings below warranting a new trial.On appeal, Defendant argued that, given his compromised medical and emotional state, the statements he made to police while he was in the hospital should have been suppressed and that the court should reduce the verdict to murder in the second degree. The Supreme Judicial Court affirmed the conviction, holding that no reversible error occurred in the proceedings below. View "Commonwealth v. Rivera" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial judge denying Defendant's motion for a new trial, holding that a defendant's waiver of his right to a jury of six persons need not be in writing as long as the trial judge ensures, by way of colloquy, that the defendant's decision to proceed is made knowingly and voluntarily.Defendant was convicted of cruelty to animals. During trial, one of the six jurors was excused from service. After conducting a colloquy, the judge found that Defendant knowingly and voluntarily waived his right to a jury of six persons, and the trial continued with five jurors. On appeal, Defendant argued that the trial judge erred in denying his motion for a new trial on the grounds that his waiver was invalid because it was not in writing pursuant to Mass. R. Crim. P. 19(b). The Supreme Judicial Court affirmed, holding that Defendant's waiver to his right to a six-person jury was valid. View "Commonwealth v. Bennefield" on Justia Law

The Supreme Judicial Court reversed a lower court judge's order of execution on the fifth agreement for judgment between Y.A., an alleged victim of domestic violence, and the Boston Housing Authority (BHA), a covered housing provider, holding that the motion judge failed to consider whether domestic violence contributed to Y.A.'s failure to make the agreed-upon payments.The Housing Court found that Y.A.'s failure to make required payments set forth in the parties' agreement constituted a violation of a material term of the agreement. The judge made no reference to Y.A.'s allegations of an abusive relationship in his findings. The Supreme Judicial Court remanded the matter to the Housing Court for further proceedings, holding that where a judge is given reason to believe that domestic violence is or might be relevant to a landlord's basis for eviction, the judge must ensure that the judge has sufficient evidence to make a determination whether the tenant is entitled to protections under the federal Violence Against Women Act (VAWA), 34 U.S.C. 12291 et seq., and such a determination must be supported by findings. View "Boston Housing Authority v. Y.A." on Justia Law

In this case concerning whether retail salespeople who are paid entirely in commissions or draws are entitled to additional overtime or Sunday pay, the Supreme Judicial Court held that such employees are entitled to overtime or Sunday pay with separate and additional payments of one and one-half times the minimum wage for every hour the employees worked over forty hours or on Sunday.At issue before the Court was whether the defendant employers in this case satisfied their obligations under the overtime statute, Mass. Gen. Laws ch. 151, 1A, and the Sunday pay statute, Mass. Gen. Laws ch. 136, 6, when they paid draws or commissions that equaled or exceeded the minimum wage for the plaintiff employees' first forty hours of work and one and one-half times the minimum wage for all hours worked over forty hours or on Sunday. The Supreme Judicial Court held that draws and commissions cannot be allocated retroactively as hourly and overtime wages and Sunday pay even where the draws and commissions equal or exceed the minimum wage for the employees' first forty hours of work and one and one-half times the minimum wage for all hours worked over forty hours or on Sunday. View "Sullivan v. Sleepy's LLC" on Justia Law

The Supreme Judicial Court reversed the superior court's grant of summary judgment to Defendant and dismissing Plaintiff's personal injury action on the grounds that Mass. Gen. Laws ch. 84, 15, the road defect statute, provided the exclusive remedy for Plaintiff's claim and that Plaintiff had not provided the statutorily required notice, holding that section 15 did not limit Defendant's common-law liability under tort law and that Defendant may be sued for negligence without providing thirty days' notice under Mass. Gen. Laws ch. 84, 18, the notice statute.Plaintiff was injured when, while riding his bicycle, he struck a utility cover that was misaligned with the road surface. Plaintiff brought suit against Defendant, Veolia Energy North America, for negligence. The superior court judge dismissed the lawsuit. The Supreme Judicial Court reversed, holding (1) the road defect and notice statutes apply to governmental and quasi-governmental actors responsible for the public duty of maintaining the public way and not to a private party such as Veolia that has created a particular defect in the road; and (2) Veolia may be sued for its own negligence without providing thirty days' notice. View "Meyer v. Veolia Energy North America" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of indecent assault and battery, holding that the trial judge did not abuse his discretion in denying Defendant's request that a question be posed to potential jurors about bias toward non-English speakers.Specifically, the Court held that while there may be a bias toward non-English speakers, such as Defendant, and that a thorough voir dire is necessary to ensure an unbiased jury, the trial judge did not abuse his discretion in denying Defendant's request to pose a question to the venire regarding language-related bias; (2) even if the judge erroneously admitted testimony from an investigator, there was no prejudice warranting a new trial; (3) the judge did not permit improper bolstering of the victim's credibility through the first complaint witness; and (4) the trial judge properly instructed the jury regarding the first complaint testimony. View "Commonwealth v. Espinal" on Justia Law