The case concerned a claimant's eligibility for unemployment benefits under G.L. c. 151A, § 25(e)(1) after she accepted a voluntary termination incentive package from her employer, Verizon. The board of review denied benefits, finding that the claimant left work voluntarily without good cause attributable to the employer, and both the District Court and the Supreme Judicial Court affirmed that decision. The court reasoned that the claimant failed to meet her burden of proving involuntariness, as she was not compelled to apply for the package, did not believe her job was in jeopardy, and accepted the offer partly for personal reasons such as job dissatisfaction and commute length. The court distinguished the facts from prior cases like Morillo where an announced layoff made termination attributable to the employer, noting instead that no layoffs occurred in the claimant's department and Verizon had not indicated any job risk.
The case concerned whether a general contractor that paid workers' compensation benefits to employees of an uninsured subcontractor under G.L. c. 152, § 18 could claim immunity from the employees' common-law negligence and wrongful death claims under the exclusivity provision of § 23. A Superior Court judge granted summary judgment to the defendant general contractor, but the Appeals Court reversed. The Supreme Judicial Court held that § 23's release of common-law claims applies only to the direct insured employer of the injured worker, not to a general contractor that pays benefits solely because of § 18. The court reached this conclusion by examining the statutory definitions of "insured" and "employee," the 1971 amendment to § 15 that abolished the common-employment doctrine and limited immunity to direct employers, and the overall purpose of the workers' compensation act. It vacated the summary judgment and remanded for further proceedings.
In Commonwealth v. Powell, the defendant was convicted after a jury-waived trial of multiple firearm offenses, including possession of a firearm without an FID card and carrying a firearm without a license, as well as resisting arrest, based on evidence obtained during a police encounter in Boston. He appealed the denial of his motion to suppress the recovered firearm, arguing that it resulted from an unlawful seizure of his person under the Massachusetts Declaration of Rights, and also challenged the sufficiency of the evidence and raised Second Amendment claims. The court affirmed the denial of the motion to suppress and upheld all convictions. The core reasoning was that officers developed reasonable suspicion for an investigatory stop when they observed the defendant, who was acting suspiciously near a potential altercation, move his hands as if grasping a gun and then flee, which justified the pursuit and subsequent recovery of the dropped revolver; the defendant's flight and resistance further supported the officers' actions without violating constitutional protections.
In Commonwealth v. Cruz, the case involved a defendant charged with drug offenses after police, responding to a parked car and detecting the odor of burnt marijuana, ordered the passenger defendant to exit the vehicle and discovered crack cocaine. The trial court suppressed the evidence and the defendant's statement, and the Supreme Judicial Court affirmed that ruling on interlocutory appeal. The court held that the 2008 decriminalization of possession of small amounts of marijuana meant the odor alone did not create reasonable suspicion of criminal activity sufficient to justify the exit order without additional facts indicating a crime. The decision turned on interpreting the new statutes' effect on search-and-seizure standards for vehicles and passengers.
In Commonwealth v. MacDonald, the defendant was convicted of distributing marijuana and committing a drug offense near a school based on police observations of suspected street-level transactions and an expert witness's identification of the seized substance. On appeal, the defendant argued that the Commonwealth's expert testimony was insufficient to prove the substance was marijuana without forensic chemical analysis, and he sought new rules requiring cautionary jury instructions in such cases or limiting the use of case facts in expert hypotheticals. The court affirmed the convictions, holding that the expert's extensive training, experience with narcotics, and direct examination of the substance provided adequate evidence of its identity as marijuana under the circumstances of this case. The court also declined to impose the requested cautionary instruction or restrictions on hypotheticals, finding them unnecessary based on existing precedent and the facts presented.
This case concerns the Massachusetts Insurers Insolvency Fund's potential liability under G. L. c. 175D for claims in an underlying medical malpractice action brought by the Smith family against a doctor whose insurer had become insolvent. The Fund sought a declaration that its maximum exposure was limited to the statutory cap of $299,999 for all claims arising from a single medical incident. A Superior Court judge denied the Fund's motion for summary judgment, ruling that the statutory cap applied separately to each covered claim by the family members, while the total remained subject to the $1 million policy limit. On direct appellate review, the Supreme Judicial Court affirmed, holding that the plain language of G. L. c. 175D, § 5(1)(a) requires the Fund to treat each family member's claim as a separate covered claim eligible for up to the statutory cap. The court relied on the statute's text and remedial purpose without reference to policy language that aggregated claims per medical incident.
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