Justia Civil Rights Opinion Summaries

At issue in this case was (1) whether a superior court judge erred in ordering the dismissal of an age discrimination complaint filed with the Massachusetts Commission Against Discrimination for lack of subject matter jurisdiction before a final decision had been reached by the commission, and (2) whether the ministerial exception required by the First Amendment prohibits a court or administrative agency from applying Massachusetts' antidiscrimination laws to the decision of a Jewish temple not to rehire a teacher in its Sunday and after-school religious school. The Supreme Court affirmed the dismissal of the complaint, holding (1) the judge erred in deciding whether the ministerial exception barred the discrimination claim before the commission had entered a final decision on the claim; but (2) the dismissal of the complaint was proper because the ministerial exception barred the teacher's claim of discrimination. View "Temple Emanuel of Newton v. Mass. Comm'n Against Discrimination" on Justia Law

In two separate actions, seven Massachusetts hospitals and one managed health care organization that disproportionately provided medical care to the poor alleged that the Secretary of the Executive Office of Health and Human Services violated her obligation to reimburse them for the reasonable costs incurred in providing medical services to MassHealth enrollees. A superior court judge granted the Secretary's motion for judgment on the pleadings in one case and the Secretary's motion to dismiss in the other, concluding as a matter of law that the plaintiffs could not prevail even if their allegations were true. The plaintiffs appealed, and the cases were consolidated. The Supreme Court affirmed the decisions denying the plaintiffs' claims, holding that the plaintiffs' redress for their claims rested in the political arena, not in the courts. View "Boston Med. Ctr. v. Sec'y of the Executive Office of Health & Human Servs." on Justia Law

After a jury trial, Defendant was convicted of murder in the second degree, assault by means of a dangerous weapon, and unlawful possession of one firearm. Defendant's convictions arose out of the then sixteen-year-old Defendant's asserted participation in what the trial judge described as an "alleged contract killing by one drug dealer of another." Defendant appealed from his convictions and the denial of his motion for a new trial. The Supreme Court (1) affirmed Defendant's convictions of murder in the second degree and possession of a firearm; and (2) vacated Defendant's conviction of assault by means of a dangerous weapon, as assault with intent to murder and assault by means of a dangerous weapon are distinct statutory offenses, and because Defendant was indicted for the former but convicted of the latter, he was entitled to have this conviction reduced to simple assault, a lesser-inclued offense of both crimes. Remanded. View "Commonwealth v. Bright" on Justia Law

A jury convicted Defendant of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Court affirmed Defendant's conviction, holding (1) because the admission of a statement by the victim was not error, there was no ineffective assistance of Defendant's trial counsel based on counsel's failure to object to the admission of the statement; (2) the trial judge did not err in admitting expert testimony; (3) Defendant's claim of ineffectiveness of trial counsel based on defense counsel's failure to object to questions posed by the prosecutor to a witness were unavailing; (4) there was no error in the prosecutor's closing argument; and (5) an isolated misstatement by the judge in her instructions to the jury did not create a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Ortiz" on Justia Law

Plaintiff filed a complaint alleging that Defendant committed a breach of a settlement agreement with the town by failing to remove mulch from property owned by Plaintiff. Defendant filed a special motion to dismiss under the anti-SLAPP (Strategic Lawsuit Against Public Participation) statute, contending that the civil claim was intended to retaliate, deter, and punish Defendant solely for engaging in the constitutionally protected activity of petitioning the town. The motion was denied. On interlocutory appeal, the Supreme Court affirmed the denial, holding that Defendant failed to meet its required threshold showing that Plaintiff's claim of breach of the settlement agreement was based on Defendant's exercise of its right to petition. View "Marabello v. Boston Bank Corp." on Justia Law

Based on an assault that occurred on June 6, 2007, a jury convicted Defendant of attempted murder, armed home invasion, assault and battery by means of a dangerous weapon, and assault and battery. The appeals court affirmed. Defendant appealed, contending, inter alia, that the assault constituted a consensual sexual encounter, and thus, in light of Lawrence v. Texas, the trial judge committed constitutional error by not instructing the jury that consent is a defense to the crimes of armed home invasion and assault and battery by means of a dangerous weapon. The Supreme Court affirmed, holding (1) there was no conflict between the reasoning of Lawrence and the Court's prior decisions holding that consent is not a defense to the crimes charged, and the judge appropriately instructed the jury on consent; (2) although the admission of materials retrieved on Defendant's home computer were proper, the judge's failure to view a video clip depicting a nude woman being strangled seemingly to death prior to ruling that its probative value outweighed its prejudicial effect was an abuse of discretion; but (3) upon independent review, the evidence was highly probative of Defendant's motive and intent, outweighing its plainly prejudicial effect. View "Commonwealth v. Carey" on Justia Law

Defendant was false accused of assaulting with a gun Ramon Benzan, a person who was performing work for Defendant. After the criminal complaint issued, it became apparent that Benzan had lied to a Boston police detective about the alleged assault in an attempt to extort money. The prosecutor filed a nolle prosequi. Defendant later moved to expunge his criminal records, arguing that the judge had the equitable authority to do so because Defendant had committed fraud on the court. A Boston municipal court judge deneid the motion, concluding that the case was controlled by the Supreme Court's decision in Commonwealth v. Boe and that under Mass. Gen. Laws 276, 100C, the judge had no power to issue an order of expungement. The Supreme Court affirmed, holding (1) there was no fraud on the court; and (2) accordingly, the judge correctly determined that he lacked the equitable authority to grant the relief requested. View "Commonwealth v. Moe" on Justia Law

After a jury trial, Defendants, two brothers, were convicted of several violations of the controlled substances laws, including the possession of class B and class D substances with intent to distribute. On appeal, Defendants primarily claimed that the admission of certificates of drug analysis to prove the chemical composition of the drugs seized in their shared apartment was constitutional error. The appeals court reversed based on improperly admitted drug certificates, even though Defendants both testified at trial and admitted that they possessed the drugs but for personal use. The Supreme Court affirmed the convictions, holding (1) the submission in evidence of the drug certificates without the testimony of the analyst that prepared them violated Defendants' right of confrontation; but (2) when considering Defendants' testimony along with the totality of the record, the admission of the drug certificates was harmless beyond a reasonable doubt.

In 1941, Anna Child Bird executed a will with a testamentary trust that benefitted her sons, her grandsons, and their issue. At the time the will was executed, the law provided that an adopted child was excluded from the definition of "child." In 1958, the statute was amended to redefine the term "child" to include an adopted child. By its terms, however, the 1958 amendment applied only to testamentary instruments executed after 1958. In 2009, another amendment made the 1958 amendment applicable to all testamentary instruments regardless of when executed. Plaintiff was the biological great-grandchild of Anna, and Plaintiff had two adopted brothers. Plaintiff's father was a biological grandson of Anna. Plaintiff had been receiving income distribution from the testamentary trust established by Anna in her will. The Supreme Court concluded that the retroactive application of the 2009 amendment to Anna's trust, with the effect that Plaintiff's interest in the trust would be divided into three parts to cover her and her two adopted brothers, was unconstitutional. Remanded.

A superior court jury convicted Defendant William Santos of armed robbery and murder in the first degree on a theory of felony-murder fin the shooting death of Luis Rodriguez. The Supreme Court reversed Defendant's convictions and remanded the case for a new trial, holding (1) the trial court erred in admitting many portions of Defendant's statement given to the police following the shooing, and the admission was not harmless beyond a reasonable doubt; and (2) the trial court err in admitting statements made by the codefendant to his sister shortly after the shooting, and the error was not harmless.