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Whitney v. Commonwealth

Citations: 15 Mass. App. Ct. 1004; 448 N.E.2d 771; 1983 Mass. App. LEXIS 1319

Court: Massachusetts Appeals Court; April 29, 1983; Massachusetts; State Appellate Court

Narrative Opinion Summary

A complaint for damages assessment under G. L. c. 79.14, filed on February 20, 1975, was initially tried before a judge without a jury, following the pre-1981 version of G. L. c. 79.22. During a subsequent jury trial, the presiding judge ruled that the prior judge’s report of material facts was admissible but not entitled to prima facie evidence status, except for the uncontradicted award of damages. The statute, prior to the 1981 amendments, required the first judge to provide a written decision that included damages awarded and material facts found. However, only the damages award was deemed prima facie evidence at the jury trial, while the material facts report was not included in that provision. This interpretation was aligned with the ruling in Roach v. Newton Redevelopment Authority, which confirmed that the statutory language grants prima facie effect solely to the damages award. The second judge's ruling was upheld, and the judgment was affirmed.

Legal Issues Addressed

Admissibility of Judge's Report in Subsequent Trials

Application: In a jury trial following a bench trial, the judge's report of material facts from the bench trial was admissible but not considered prima facie evidence, except for the uncontradicted award of damages.

Reasoning: During a subsequent jury trial, the presiding judge ruled that the prior judge’s report of material facts was admissible but not entitled to prima facie evidence status, except for the uncontradicted award of damages.

Judicial Interpretation of Statutory Language

Application: The interpretation aligned with prior case law, confirming that only the damages award received prima facie effect under the statute, supporting the upholding of the second judge's ruling.

Reasoning: This interpretation was aligned with the ruling in Roach v. Newton Redevelopment Authority, which confirmed that the statutory language grants prima facie effect solely to the damages award.

Prima Facie Evidence Status of Damages Award

Application: The statutory language before the 1981 amendments granted prima facie effect only to the damages award as found by the first judge, not to the material facts report.

Reasoning: The statute, prior to the 1981 amendments, required the first judge to provide a written decision that included damages awarded and material facts found. However, only the damages award was deemed prima facie evidence at the jury trial, while the material facts report was not included in that provision.