Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the award of attorney’s fees to Plaintiffs under the fee-shifting provisions of the Wage Act, Mass. Gen. Laws ch. 149, 148, 150, holding that the “catalyst test” applied to the Wage Act claims and that the trial judge correctly found that Plaintiffs satisfied that test in this case.Plaintiffs were employees who filed a claim against their employer. The end result was a favorable settlement agreement and stipulation of dismissal. Plaintiffs then filed a motion for attorney’s fees. Defendants opposed the motion, arguing that the test for determining prevailing party status under federal fee-shifting statutes was the test established by Buckhannon Board & Care Home, Inc. v. West Virginia Department of Health & Human Resources, 532 U.S. 598 (2001). The judge concluded that the catalyst test and not the Buckhannon test applied to Massachusetts fee-shifting statues and that, under this test, Plaintiffs were “prevailing parties” for purposes of an award of attorney’s fees and costs. The Supreme Judicial Court affirmed, holding (1) the catalyst test applies to Wage Act claims; and (2) the trial judge did not err in finding that Plaintiffs satisfied the catalyst test in this case. View "Ferman v. Sturgis Cleaners, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court allowing Defendants’ motion for summary judgment on Plaintiff’s action for legal fees, holding that Plaintiff’s claim for fees was time barred by the statute of limitations applicable to contract actions set forth in Mass. Gen. Laws ch. 260, 2.Plaintiff, an assignee of a law firm, brought this action for legal fees against a former employee of the law firm, as representative of the estate of the decedent, a former law firm client, for the payment of certain legal fees allegedly owed by the decedent to the law firm under a contingent fee agreement. A superior court judge granted summary judgment in favor of Defendants. The Supreme Judicial Court affirmed, holding that Plaintiff’s claim for fees was barred by the statue of limitations applicable to contract actions set forth in Conn. Gen. Laws ch. 260, 2. View "Halstrom v. Dube" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of possession of a class B substance with intent to distribute, holding that although the voir dire in this case was incomplete, it did not prejudice Defendant.During jury selection, and over Defendant’s objection, the judge excused for cause a prospective juror who said that it was her opinion that “the system is rigged against young African American males.” On appeal, Defendant argued that the judge abused his discretion in dismissing the prospective juror. While the Supreme Court declined to set aside the verdict, the Court took the opportunity to set forth the factors a judge should consider when a prospective juror states a belief or opinion based on his or her world view. View "Commonwealth v. Williams" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions of penile-vaginal and digital-vaginal rape, holding that while two errors occurred during the trial proceedings, neither error required reversal of Defendant’s convictions.On appeal, Defendant argued (1) the judge erred by failing to instruct the jury that a defendant may not be found guilty of rape after the victim withdrew her consent after initially consensual intercourse unless the penetration continued after the victim communicated the withdrawal of consent to the defendant, and (2) the judge erred in admitting evidence of cocaine use for the purpose of allowing the jury to assess Defendant’s ability to perceive and recall events where there was no expert testimony regarding the effect of cocaine on perception and memory. The Supreme Court held that the judge erred in failing to provide the jury with an instruction regarding the withdrawal of consent and in admitting cocaine evidence for the purpose of assessing Defendant’s memory, but under the circumstances, neither error required reversal of Defendant’s convictions. View "Commonwealth v. Sherman" on Justia Law

The Supreme Judicial Court affirmed the order of the motion judge in this case allowing Defendant’s motion to suppress his postarrest statements, holding that the police lacked probable cause to arrest.Defendant was charged with receiving a stolen motor vehicle, subsequent offense, and receiving stolen property over $250 in connection with items found in a stolen motor vehicle. Defendant filed a motion to suppress his postarrest statements on the grounds that the police lacked probable cause to arrest. The motion judge allowed the motion. The Supreme Judicial Court affirmed, holding that there was insufficient evidence to establish probable cause that Defendant knew the vehicle was stolen, which is a requisite element of the crime of receiving a stolen motor vehicle. View "Commonwealth v. Pridgett" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendants Kevin McCormack and Brian Porreca of murder in the first degree, holding that there was no reversible error in the proceedings below.Specifically, the Court held (1) there was sufficient evidence to support each defendant’s murder conviction; (2) there trial judge did not err in concluding that there were no Brady violations; (3) there was no “newly discovered” evidence requiring a new trial; (4) Defendants’ rights to confrontation and due process were protected when a DNA expert testified at trial; (5) discovery violations in this case did not implicate the confrontation clause; (6) Defendants’ motion for disclosure of a confidential informant’s identity was properly denied; and (7) there was no reason for the Court to order a new trial or to reduce the degree of guilt under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Barry" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court convicting Defendant of murder in the first degree on a theory of deliberate premeditation, holding that there was no reversible error in the proceedings below.Specifically, the Court held (1) the trial judge did not err in denying Defendant’s requests for an instruction on accident and on involuntary manslaughter; (2) the absence of an instruction on voluntary manslaughter did not create a substantial likelihood of a miscarriage of justice; (3) this Court was not required to apply the theory of transferred intent self-defense to correct a miscarriage of justice; (4) Defendant was not entitled to a new trial based on the erroneous deprivation of two preemptory challenges; (5) a police officer’s identification testimony, even if erroneous, was not prejudicial; and (6) trial counsel’s failure to present an intoxication defense through available witnesses did not constitute ineffective assistance of counsel. View "Commonwealth v. Pina" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court 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.In her petition, Petitioner requested relief from the foreclosure of her home. The single justice denied the petition without holding a hearing. On appeal, Petitioner raised a jurisdictional challenge to the foreclosing mortgagee’s standing, the validity of the foreclosure, and her subsequent eviction. The Supreme Judicial Court affirmed, holding that Petitioner had an adequate alternative remedy, and therefore, consideration of the issues raised by Petitioner by the Court under its extraordinary power of general superintendence was unnecessary. View "Brown v. Federal National Mortgage Ass’n" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Plaintiff’s petitions seeking relief from a summary process judgment and other orders entered against her in the housing court, holding that the single justice properly found that Plaintiff failed to demonstrate the absence of an adequate alternative remedy.Specifically, the Court held that Plaintiff’s filings made it clear that she had avenues available to her to pursue relief from the housing court orders and judgment other than by means of the petitions that she filed in this Court, and therefore, the single justice did not err in denying relief. View "Briscoe v. LSREF3/AH Chicago Tenant, LLC" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner’s petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice correctly denied relief because Petitioner had an adequate alternative remedy.This dispute between Petitioner and Respondent involving certain work that Respondent performed on a construction site started as a small claims action in the district court. The clerk-magistrate, and later a jury, found in favor of Respondent. After filing a notice of appeal Petitioner filed its petition alleging that it had no remedy other than to seek relief pursuant to Mass. Gen. Laws ch. 211, 3. The single justice summarily denied the petition. The Supreme Judicial Court affirmed, holding that the single justice correctly denied relief because Petitioner had an adequate, well-established alternative remedy. View "D.R. Peck Excavating, Inc. v. Machado" on Justia Law