Justia Massachusetts Supreme Court Opinion Summaries
In re M.C.
The Supreme Judicial Court affirmed the judgment of a municipal court judge civilly committing M.C. for a period of two months, holding that the record contained sufficient evidence to support M.C.’s involuntary commitment and that M.C. was not denied due process of law despite the hearing being conducted at a hospital rather than at a court house and in the absence of a complete, verbatim transcript.Although M.C. sought to have the civil commitment hearing conducted at a court house, the hearing was held at the psychiatric facility where M.C. had been temporarily committed. At the beginning of the proceeding the court-owned recording equipment malfunctioned, and then two different alternate recording devices were used to record the remainder of the hearing. The Supreme Judicial Court affirmed the judge’s decision to civilly commit M.C., holding that the available transcript provided an adequate basis for appellate review and contained sufficient evidence to support M.C.’s involuntary commitment. View "In re M.C." on Justia Law
F.K. v. S.C.
The Supreme Judicial Court vacated the trial judge’s issuance of harassment prevention orders against Defendant pursuant to Mass. Gen. Laws ch. 258E, 3(a), holding that Defendant’s conduct amounted to only one act of harassment, and therefore, Defendant’s conduct failed to satisfy the threshold requirement of the statute that a defendant commit at least three acts of harassment.Plaintiffs sought harassment prevention orders against Defendant after Defendant created a rap song in which he improvised lyrics pertaining to Plaintiffs. A district court judge issued the requested orders, concluding that, in posting the song on two Internet website and making the inflammatory statements within the song, Defendant had committed at least three individual acts of harassment against the plaintiffs. The Supreme Judicial Court vacated the order, holding that Defendant engaged only in one continuous act of harassment in this case. View "F.K. v. S.C." on Justia Law
Posted in:
Criminal Law
Commonwealth v. Chicas
The Supreme Judicial Court affirmed Defendant’s conviction and the denial of Defendant’s motion for a new trial and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce the verdict, holding that there was no error or abuse of discretion in the proceedings below.Defendant was convicted of murder in the first degree. The Supreme Judicial Court affirmed, holding (1) the trial judge did not abuse her discretion in limiting Defendant’s cross-examination of the Commonwealth’s witnesses; and (2) the procedure suggested by the trial judge, and approved by defense counsel, of using two interpreters did not violate Defendant’s constitutional due process rights. View "Commonwealth v. Chicas" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Commonwealth v. Braune
The Supreme Judicial Court affirmed Defendant’s conviction of money laundering, holding that the evidence was sufficient as a matter of law to establish “concealment” money laundering, in violation of Mass. Gen. Laws ch. 267A, 2(2)(ii)(A).Defendant’s conviction stemmed from her act of depositing more than $300,000 in stolen money into her checking account through a series of transactions, each under $10,000, and claiming to have received the money in an inheritance. On appeal, Defendant argued that the evidence was insufficient to establish a design to conceal under the statute where Defendant openly deposited the money into her checking account using her own name. The Supreme Judicial Court affirmed, holding that the evidence was sufficient for a rational jury to conclude that Defendant’s deposits were designed, at least in part, to conceal the nature, location, source, ownership or control of the stolen funds. View "Commonwealth v. Braune" on Justia Law
Posted in:
Criminal Law
Myrick v. Appeals Court
The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Appellant’s petition for relief in the nature of mandamus, holding that Appellant did not demonstrate any entitlement to relief in the nature of mandamus.In his mandamus petition, Appellant sought an order directing the Appeals Court to recall the rescript it issued after affirming a final judgment of the superior court. The Supreme Judicial Court affirmed the denial of Appellant’s petition, holding that Appellant was not barred from pursuing the ordinary process by applying for further appellate review. View "Myrick v. Appeals Court" on Justia Law
Posted in:
Civil Procedure
Yee v. Massachusetts State Police
The Supreme Judicial Court vacated the superior court’s allowance of Defendant’s motion for summary judgment and remanded this discrimination case, holding that the trial judge erred in determining that Plaintiff had failed to meet his burden of showing a prima facie case of discrimination.Plaintiff, a lieutenant in the Massachusetts State police, brought this Mass. Gen. Laws ch. 151B, 4 action alleging that he suffered discrimination when he was denied a transfer to a different troop station on the basis of his age, race, or national origin. The superior court granted summary judgment in favor of the State police, holding that Plaintiff did not meet his burden of showing that the denial of his request for a lateral transfer was an “adverse employment action.” The Supreme Judicial Court vacated the superior court’s judgment, holding (1) under certain circumstances, the failure to grant a lateral transfer to a preferred position may constitute an adverse employment action under ch. 151B; and (2) because Plaintiff met his burden of showing a prima facie case of discrimination, this case is remanded to the motion judge to decide the issue of whether Plaintiff’s request for a lateral transfer was motivated by discriminatory animus. View "Yee v. Massachusetts State Police" on Justia Law
Posted in:
Civil Rights, Labor & Employment Law
Crittenden v. Commonwealth
The Supreme Judicial Court affirmed the judgment of the single justice of the court treating Petitioner’s paper titled “Respondent’s Petition for Interlocutory Appeal and Stay of Proceedings” as a petition pursuant to Mass. Gen. Laws ch. 211, 3 and denying relief without a hearing, holding that Petitioner failed to meet his burden of establishing why he could not obtain relief on appeal.After the Commonwealth filed a petition in the superior court seeking civil commitment of Petitioner as a sexually dangerous person pursuant to Mass. Gen. Laws ch. 123A, Petitioner moved or an order preventing future dissemination of a Mass. Gen. Laws ch. 123, 18(a) report by the district court for the purposes of the Mass. Gen. Laws ch. 123A proceeding. Petitioner then filed his petition seeking review of that interlocutory order. The single justice denied relief pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court affirmed, holding that the single justice properly declined to exercise the court’s extraordinary power of superintendence in light of an adequate alternative remedy. View "Crittenden v. Commonwealth" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Javier
The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree as a joint venturer and declined to exercise its authority to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that the evidence was sufficient to prove that Defendant was present at the scene, knowingly participated in the shooting, and had the mental state necessary to the offense.Specifically, the Court held (1) the evidence was sufficient to warrant the jury’s finding that Defendant was guilty of murder in the first degree on a theory of deliberate premeditation as a joint venturer; (2) while the exclusion of certain evidence would have been better practice, the admission of the evidence would not have had any impact on the jury’s verdict; and (3) allowing the presence of a police witness at the prosecutor’s table was not an abuse of the judge’s discretion. View "Commonwealth v. Javier" on Justia Law
Posted in:
Criminal Law
Briscoe v. LSREF3/AH Chicago Tenant, LLC
The Supreme Judicial Court affirmed the judgment of a single justice of the court dismissing Plaintiff’s complaint seeking relief in the nature of mandamus, holding that there was no error.After Defendant prevailed in a summary process proceeding against Plaintiff, Plaintiff filed a complaint alleging error with that proceeding and seeking relief from the judgment. The single justice concluded that Plaintiff was not entitled to relief because she failed to pursue other available remedies. The Supreme Judicial Court affirmed, holding that relief in the nature of mandamus was not available where the ordinary appellate process would suffice and that Plaintiff failed timely to claim this appeal from the judgment entered in the county court. View "Briscoe v. LSREF3/AH Chicago Tenant, LLC" on Justia Law
Posted in:
Criminal Law
Aldana v. Commonwealth
The Supreme Judicial Court dismissed Appellant’s appeal from a judgment of the county court denying his petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion by denying relief where Appellant did not carry his burden of showing why review of a trial court decision could not adequately be obtained on appeal or by other available means.Appellant was indicted on charges of home invasion and other offenses. Petitioner’s Mass. Gen. Laws ch. 211, 3 petition sought relief from a superior court judge’s ruling allowing the Commonwealth’s motion for an order requiring Appellant to submit a buccal swab for purposes of deoxyribonucleic acid testing. The single justice denied relief. The Supreme Judicial Court dismissed Appellant’s appeal, holding that Appellant, if convicted, an had adequate, alternate remedy in the normal appellate process. View "Aldana v. Commonwealth" on Justia Law
Posted in:
Criminal Law