Massachusetts SJC New Opinions

Commonwealth v. Meta Platforms Inc - Section 230 Immunity Ruling

The Massachusetts Supreme Judicial Court ruled that Section 230 immunity does not bar Commonwealth claims against Meta Platforms and Instagram alleging unfair business practices (designing platform to induce compulsive use by children), deceptive practices (misleading public about platform safety), and public nuisance. The court held that § 230(c)(1) protects interactive computer service providers only from claims seeking to hold them liable for harms stemming from user-generated content, not from claims based on the company's own conduct in designing and marketing the platform.

Commonwealth v. LeBlanc - Forfeiture by Wrongdoing (Spousal Privilege)

The Massachusetts Supreme Judicial Court affirmed the denial of the Commonwealth's motion to admit out-of-court statements made by the defendant's spouse, rejecting the forfeiture by wrongdoing doctrine. The court held that mere collusion or non-cooperation by a spouse does not constitute forfeiture of the spousal privilege, which requires proof of active assistance to prevent testimony with the intent to do so.

Commonwealth v. Sonny S. - Juvenile Jail Credit Denial

The Massachusetts Supreme Judicial Court ruled that a juvenile sentenced as a youthful offender under a combination sentence (Department of Youth Services commitment followed by a suspended adult prison sentence) is not entitled to jail credit against the subsequently imposed adult prison term for time spent in DYS custody. The court determined that no statutory authority exists for applying DYS commitment time as credit against an adult prison sentence. The ruling arises from a case where the juvenile sought credit for 549 days spent in a secure DYS facility before being released on conditional liberty and later having his suspended sentence imposed for probation violations.

Commonwealth v. McGrath - Breaking and Entering Intent Misdemeanor

The Massachusetts Supreme Judicial Court affirmed a District Court conviction for breaking and entering with intent to commit a misdemeanor under G.L. c. 266, § 16A. The defendant challenged the conviction arguing the Commonwealth violated due process by presenting new intended misdemeanors (larceny or criminal trespass) on appeal. The SJC rejected both the due process and sufficiency of evidence claims.

Commonwealth v. Donovan - Right to Counsel at Juvenile Transfer Hearings

The Massachusetts Supreme Judicial Court held that defendants facing transfer hearings under Mass. Gen. Laws c. 119, § 72A are entitled to effective assistance of counsel at these critical proceedings. The court vacated Brian Donovan's conviction after finding his counsel was unprepared to present evidence regarding his maturity and rehabilitation over the two decades between the crimes and the hearing. Defense attorneys at § 72A transfer hearings must now present comprehensive rehabilitation and maturity evidence.

Commonwealth v. Williams - Murder Conviction Vacated

The Massachusetts Supreme Judicial Court vacated the murder in the first degree and assault with attempt to kill convictions against defendant Williams and remanded for a new trial. Consistent with Commonwealth v. Guardado, the court also vacated the firearms convictions. The case involved a May 2018 shooting incident in Brockton where the defendant was convicted based partly on testimony from a cooperator whose charges were dismissed.

Supreme Judicial Court Rules on Attorney's Fees in Anti-SLAPP Statute Cases

The Massachusetts Supreme Judicial Court ruled that the Appeals Court erred in reducing an attorney's fee award under the anti-SLAPP statute. The court clarified that fee awards for anti-SLAPP work should not be reduced based on the monetary value of underlying claims for which fees were not sought.

In the Matter of an Impounded Case - SJC-13866

The Massachusetts Supreme Judicial Court affirmed a single justice's denial of a petitioner's request for relief under G. L. c. 211, § 3, concerning a care and protection proceeding. The court found the petitioner had adequate alternative remedies through the Appeals Court and did not demonstrate why review could not be obtained through standard appellate channels.

SJC Denies Bar Advocate Pay Raise Request

The Massachusetts Supreme Judicial Court (SJC) denied a request from the Committee for Public Counsel Services (CPCS) to allow judges to increase bar advocate compensation rates above legislative limits. The court found no extraordinary circumstances to justify judicial intervention in setting rates for indigent defense.

Ryan v. Mary Ann Morse Healthcare Corp. - Assisted Living Security Deposit Statute

The Massachusetts Supreme Judicial Court ruled in Ryan v. Mary Ann Morse Healthcare Corp. that community fees charged by assisted living residences (ALRs) can be considered lawful if they correspond to ALR-specific intake services. This decision clarifies the application of the security deposit statute to ALRs.