Massachusetts Lawyers Weekly

 

SJC's important opinions through the years

Published: September 20, 2007

1972

Judges may compel fiscal appropriations

A judge has the inherent power to bind the state contractually for expenses reasonably necessary to the operation of his court and may issue ex parte orders for the payment of such obligations even though there exists no prior state appropriation to cover those expenses.

O'Coin's, Inc. v. Treasurer of the County of Worcester, et al., 362 Mass. 507

1973

Leases are recognized as contracts

A lease will from this point forward be considered a contract between a landlord and tenant, not the conveyance of an estate in real property for a term.

Boston Housing Authority v. Hemingway, 363 Mass. 184

1974

Discovery rule applied to legal malpractice

The statute of limitations begins to run in legal malpractice cases only when the lawyer's alleged misconduct was discovered or should reasonably have been discovered.

Hendrickson, et al. v. Sears, 365 Mass. 83

1975

Recovery allowed for wrongful death of fetus

A fetus is a person for purposes of the Massachusetts wrongful death statute.

Mone, administrator v. Greyhound Lines, Inc., et al., 368 Mass. 354

1976

No PIP benefits for workers' compensation recipient

A person insured under a motor vehicle liability policy is precluded from receiving "personal injury protection" benefits if he is entitled to workers' compensation for injuries received while operating a vehicle within the course of his employment.

Flaherty v. The Travelers Insurance Company, 369 Mass. 482

1977

Landlords have duty to care for common areas

Landlords owe tenants a continuing duty to exercise reasonable care in keeping common areas safe.

King v. G & M Realty Corporation, 373 Mass. 658

1978

Products liability claim accrues on date of injury

The limitations period in products liability actions based on negligence must be measured from the date of injury, not the date of manufacture.

Cannon v. Sears, Roebuck and Company, Inc., 374 Mass. 739

1979

Incapacity benefits allowed for mental injury

An employee is legally entitled to workers' compensation if he becomes incapacitated by a mental or emotional disorder growing out of specific stressful work-related incidents.

Albanese's Case, 378 Mass. 14

1980

Death penalty ruled unconstitutional

The state's death penalty statute must be struck down as unconstitutional, in that it is unacceptably cruel under contemporary standards of decency and would inevitably be administered with arbitrariness and discrimination.

District Attorney for the Suffolk District v. Watson, 381 Mass. 648

1981

Ante nuptial agreement is upheld

An ante nuptial agreement that set forth the rights of a husband and wife in the event of divorce was binding as to alimony and the division of property.

Osborne v. Osborne, 384 Mass. 591

1982

Law firm barred from opposing former client

A law firm may not act as plaintiff's counsel against a company that it defended in other matters without the consent of all parties.

McCourt Properties v. FTC Properties, 386 Mass. 145

1983

Arbitrary drunk-driving roadblocks ruled illegal

Arbitrary roadblock stops to detect drunk drivers are unconstitutional.

Commonwealth v. McGeoghegan, 389 Mass. 137

1984

Grantee gets choice when deed description varies

If a deed to convey land employs two conflicting descriptions of the property, the grantee may adopt the description most beneficial to him.

Bernard v. Nantucket Boys Club, Inc., 391 Mass. 823

1985

State constitution demands more than U.S. Constitution for valid search

Article 14 of the Massachusetts Declaration of Rights provides more substantial protection to criminal defendants than does the Fourth Amendment in determinations of probable cause for search warrants.

Commonwealth v. Upton, 394 Mass. 363

1986

Paternity test found to be admissible

Results of human leukocyte antigen testing are admissible under controlled conditions as evidence in paternity proceedings.

Commonwealth v. Beausoleil, 397 Mass. 206

1987

'Issue' of decedent includes illegitimate children

If the term "issue" is left unexplained in a will or trust instrument executed after April 16, 1987, it will be considered to include all biological descendants whether legitimate or illegitimate.

Powers, trustee v. Wilkinson, 399 Mass. 650

1988

Corporations must be represented by lawyers

In all judicial proceedings other than small claims matters, corporations may not be represented by corporate officers who are not licensed to practice law in Massachusetts.

Varney Enterprises, Inc. v. WMF, Inc., 402 Mass. 79

1989

Fiduciary duty of law partners clarified

Lawyers violated their fiduciary duty to their former partnership where, after deciding to form a new partnership, they secretly sought existing clients' authorization to remove cases to the new firm and did not clearly inform those clients of their right to choose who would continue to represent them.

Meehan, et al. v. Shaughnessy, et al., 404 Mass. 419

1990

Parents get damages for loss of adult child's companionship

Damages for loss of an adult unmarried child's companionship and society are available in a wrongful death action to the decedent's parents as next of kin.

Schultz v. Grogean, 406 Mass. 364

1991

Summary judgment burden explained

A party in a civil action moving for summary judgment on a claim on which the opposing party will have the burden of proof at trial is entitled to summary judgment if it demonstrates, by reference to materials described in Mass. R. Civ. P. 56(c), unmet by countervailing materials, that the opposing party has no reasonable expectation of proving an essential element of that party's case.

Kourouvacilis v. General Motors Corporation, 410 Mass. 706

1992

Lead paint held not 'pollutant' for insurance purposes

The lead in paint is not a "pollutant" as that term is generally used in the pollution exclusion clauses of comprehensive liability policies and therefore insurers cannot normally rely on such clauses to avoid their duty to defend landlords against damage suits filed on behalf of child tenants allegedly injured by eating lead paint.

Atlantic Mutual Insurance Company v. McFadden, 413 Mass. 90

1993

Age discrimination victims cannot be awarded punitive damages under state law

Punitive damages are not available to a plaintiff who wins an age discrimination suit under the state anti-discrimination statute.

Fontaine v. Ebtec Corporation, 415 Mass. 309

1994

Jurors may not be excluded based on gender

Under the Massachusetts Constitution, it is impermissible to use gender to eliminate prospective jurors.

Commonwealth v. Fructman, 418 Mass. 8

1995

Burden of proof defined in employment bias cases

Once a plaintiff charging employment discrimination under G.L.c. 151B shows that a defendant employer's nondiscriminatory reasons for termination are false, the plaintiff will prevail even without presenting direct proof of discrimination or excluding all other possible explanations for the discharge.

Blare v. Husky Injection Molding Systems Boston, Inc., 417 Mass. 437

1996

Evidence of settlement ruled generally inadmissible

No evidence of a settlement or its amount is admissible in a tort case unless such evidence is relevant on some issue other than damages.

Morea, administratrix v. Cosco, Inc., 422 Mass. 601

1997

No warnings required before alphabet test

The police need not give Miranda warnings to a motorist who has been stopped for alleged drunk driving before asking the motorist to recite the alphabet.

Vanhouton v. Commonwealth, 424 Mass. 327

1998

Claimant's conduct may free insurer from G.L.c. 176D liability

If an auto insurance claimant seeking in excess of the policy limit will not settle all claims against the policyholder that are covered by the policy, the insurance company does not violate G.L.c. 176D by refusing to pay the policy limit.

Lazaris v. Metropolitan Property & Casualty Insurance Company, 482 Mass. 502

1999

Real property purchase offer signed by both parties established binding contract

A real estate purchase offer, which was signed by a plaintiff and a defendant property owner, created a binding agreement to sell the property, even though a purchase and sale agreement was never executed.

McCarthy v. Tobin, 429 Mass. 84

2000

Testator's children barred from suing for legal malpractice

An attorney could not be sued for malpractice by the children of a testator whose will the lawyer had prepared.

Miller, et al. v. Mooney, 431 Mass. 57

2001

Juror questioning of witnesses held generally permissible

The practice of allowing jurors to ask witnesses questions is generally acceptable in both criminal and civil cases, with some restrictions.

Commonwealth v. Britto, 434 Mass. 285

2002

Suit allowed against medical practice group

A woman whose baby was delivered stillborn at a hospital after an auto accident could sue the medical practice group that employed the treating doctor, even though the group had no apparent decision-making authority over the doctor.

Dias, et al. v. Brigham Medical Associates, Inc., 438 Mass. 317

2003

State constitution found to grant same-sex couples the right to marry

Under the Massachusetts Constitution, same-sex couples cannot be excluded from the benefits and obligations of marriage.

Goodridge, et al. v. Department of Public Health, et al., 440 Mass. 309

2004

No post-MCAD right to jury trial for bias-claim respondents

Respondents to bias claims at the Massachusetts Commission Against Discrimination are not legally entitled to a de novo jury trial in Superior Court following an unfavorable administrative ruling.

Stonehill College v. Massachusetts Commission Against Discrimination, et al., 441 Mass. 549

2005

Chapter 151B claims freed from immunity cap

The charitable immunity cap does not apply to claims brought under G.L.c. 151B.

Ayash v. Dana-Farber Cancer Institute, et al., 443 Mass. 367

2006

No duty owed by commercial landlord to non-tenants

A commercial landlord owes no duty of care to non-tenants legitimately on the leased premises.

Humphrey v. Byron, et al., 447 Mass. 322

2007 (to date)

Perpetuities rule not infringed by unlimited first-refusal right

A right of first refusal unlimited by any time restriction is not in violation of the rule against perpetuities.

Bortolotti v. Hayden, 449 Mass. 193

Attorney for Plaintiff: Thomas P. Carpenter, Ardito, Sweeney, Stusse, Robertson & Dupuy, West Yarmouth