Justia Massachusetts Supreme Court Opinion Summaries

A delinquency complaint charged Juvenile with one count of possession of a class D substance (marijuana) with intent to distribute. Juvenile filed a motion to dismiss, arguing that the complaint was not supported by probable cause that he intended to distribute the marijuana found in his possession. The juvenile court judge allowed the motion but concluded that he was obliged to arraign Juvenile before dismissing the complaint. The Supreme Court affirmed, holding (1) the information in the complaint fell short of probable cause to believe Juvenile intended to distribute the marijuana in his possession; and (2) a juvenile court judge may allow a motion to dismiss before the arraignment of a juvenile where the judge concludes that prearraignment dismissal is in the best interests of the child and the interests of justice. View "Commonwealth v. Humberto H." on Justia Law

On August 20, 2009, Defendant was charged with possession of a class B substance with intent to distribute and committing this violation within 1,000 feet of a preschool facility in violation of Mass. Gen. Laws ch. 94C, 32J. While Defendant's case was pending, on August 2, 2012, the Governor signed into law a crime bill that amended chapter 94C section 32J by reducing the radius of the school zone from 1,000 feet to 300 feet. Thereafter, Defendant moved to dismiss his school zone violation, alleging that the crime bill applied to all cases alleging a school zone violation that had not been adjudicated before August 2, 2012. The trial judge denied the motion. The Supreme Court vacated the judge's order, holding that the portion of the crime bill reducing the radius of the school zone applies to all cases alleging a school zone violation for which a guilty plea had not been accepted or conviction entered as of August 2, 2012, regardless whether the alleged violation was committed before that date. Remanded. View "Commonwealth v. Pagan" on Justia Law

After a jury-waived trial, Defendant was convicted of operating a motor vehicle after his license had been suspended for operating while under the influence of alcohol (OUI). The court of appeals affirmed the conviction. The Supreme Court reversed Defendant's conviction, holding (1) the admission of certain documents from the registry of motor vehicles without live testimony from a registry employee violated Defendant's confrontation rights to the extent that the registry documents included an attestation of notice, and the error was not harmless beyond a reasonable doubt; and (2) the Commonwealth presented sufficient evidence that Defendant violated Mass. Gen. Laws ch. 90, 23, third par, which governs operating a motor vehicle after suspension of a license on the basis of an OUI, and therefore, the judge erred in imposing a sixty-day sentence. View "Commonwealth v. Lee" on Justia Law

Defendant was charged with possession of a class D substance with intent to distribute and committing this violation within 1,000 feet of a preschool facility in violation of Mass. Gen. Laws ch. 94C, 32J. While Defendant's case was pending, on August 2, 2012, the Governor signed into law a crime bill that amended chapter 94C section 32J by reducing the radius of the school zone from 1,000 feet to 300 feet. Defendant moved to dismiss the school zone violation, claiming that the crime bill applied to all cases alleging a school zone violation that had not been adjudicated before August 2, 2012. The Supreme Court held that the portion of the crime bill that reduces the radius of the Drug-Free School Zone from 1,000 feet to 300 feet applied to all cases alleging a school zone violation for which a guilty plea had not been accepted or conviction entered as of August 2, 2012, regardless of whether the alleged violation was committed before August 2, 2012. Remanded. View "Commonwealth v. Bradley" on Justia Law

In 1996, Defendant pled guilty to various offenses, including uttering a false instrument, larceny, and receiving stolen property. Fifteen years later, Defendant filed a motion to withdraw his guilty pleas, contending that the plea judge did not conduct a sufficient colloquy regarding his rights to a trial by jury. The plea judge that accepted Defendant's guilty pleas allowed Defendant's motion to withdraw his pleas after declining to apply a presumption of regularity to the proceeding because the judge lacked confidence that his plea colloquy had been adequate. The Supreme Court vacated the judge's order, holding that the judge's belief that certain plea colloquies he conducted over a period of years may have been inadequate was insufficient to dispel the presumption of regularity or to support the withdrawal of Defendant's pleas. Remanded. View "Commonwealth v. Cartagena" on Justia Law

After a police officer stopped Defendant's vehicle and conducted two field sobriety tests, the officer arrested Defendant. Defendant pleaded guilty to several alcohol-related driving offenses. After a jury trial, Defendant was convicted of additional alcohol-related driving offenses. The Supreme Court affirmed the judgments, holding (1) the trial judge erred in admitting the officer's opinion that Defendant's "ability to drive was diminished" by his consumption of alcohol, but the error was harmless; (2) the trial judge did not err in admitting the officer's opinion that Defendant was "probably impaired"; and (3) where the indictment charging Defendant identified the statute that Defendant allegedly violated but failed to allege an essential element of proof in describing the offense, due process did not require vacating the Defendant's conviction arising from his guilty plea where he had fair notice of the crime charged and failed to show that he did not understand that he was pleading guilty to the crime. View "Commonwealth v. Canty" on Justia Law