Justia Massachusetts Supreme Court Opinion Summaries

Defendant was convicted of murder in the first degree and sentenced to a mandatory term of life imprisonment without the possibility of parole. Defendant was seventeen years old at the time of the offense. The U.S. Supreme Court subsequently decided Miller v. Alabama, which held that the imposition of a mandatory sentence of life imprisonment without parole on persons under the age of eighteen at the time they committed the murder violates the Eighth Amendment. Consequently, Defendant filed a petition challenging the constitutionality of the sentencing scheme for murder in the first degree as applied and sought a declaration that article 26 of the Massachusetts Declaration of Rights bars the imposition of a sentence of life imprisonment for juvenile homicide offenders. The Supreme Court held (1) Miller has retroactive application to cases on collateral review; and (2) the mandatory imposition of a sentence of life in prison without the possibility of parole on individuals who were under age eighteen when they committed first degree murder violates the prohibition on cruel or unusual punishments in article 26, and the discretionary imposition of such a sentence on juvenile homicide offenders also violates article 26 because it is an unconstitutionally disproportionate punishment. View "Diatchenko v. Dist. Attorney" on Justia Law

Defendant committed murder when he was seventeen years old. Defendant was subsequently convicted in the superior court of murder in the first degree and related weapons charges. While Brown was awaiting trial, the U.S. Supreme Court decided Miller v. Alabama, which held that mandatory life-without-parole sentences for juvenile homicide offenders violate the Eighth Amendment. The statutory sentencing scheme in Massachusetts requires, however, that all defendants over the age of fourteen who are convicted of murder in the first degree must be sentenced to life without the possibility of parole. Consequently, Defendant's sentencing was stayed until the Maine Supreme Court could render an opinion regarding the issue. The Supreme Court concluded that Defendant was entitled to the benefit of Miller and Commonwealth v. Diatchenko, in which the Court held that all life-without-parole sentences for juvenile offenders violate the Massachusetts Declaration of Rights. Consequently, the Court held that Defendant may not be sentenced to life without parole. Remanded for sentencing. View "Commonwealth v. Brown" on Justia Law

The Commonwealth filed five delinquency complaints against Defendant when he was seventeen years old based on the alleged sexual abuse of a victim. Defendant was summonsed into court on the complaints while he was still seventeen, but Defendant had turned eighteen by the time of his first scheduled court appearance and arraignment. The Commonwealth subsequently obtained youthful offender indictments against Defendant based on the portion of the alleged abuse that took place when Defendant was between fourteen and seventeen years old. The juvenile court subsequently reported to the Supreme Court questions concerning issues of the juvenile court's jurisdiction. The Supreme Court held (1) the term "apprehended" in Mass. Gen. Laws ch. 119, 72 is marked by the commencement of process, typically through a summons, provided the individual is able to the court at that time; (2) an individual may not be indicted as a youthful offender after he has turned eighteen for offenses he allegedly committed between the ages of fourteen and seventeen; and (3) a youthful offender indictment may not issue against an individual after his eighteenth birthday, regardless of whether a delinquency complaint on the same facts has been filed before the individual's eighteenth birthday. View "Commonwealth v. Mogelinski" on Justia Law

In each of these three consolidated cases plaintiff banks brought summary process actions against defendants, former homeowners-mortgagors, after foreclosure. Each defendant raised several defenses and counterclaims in his or her answer to the complaint, including challenges to the bank's right to possession and title as derived through foreclosure sale. Each bank filed a motion to strike the affirmative defenses and to dismiss the counterclaims, arguing that the only defenses and counterclaims available in summary process are those related to landlord-tenant relationships between the parties and those challenging title based on a failure to strictly comply with the power of sale provided in the mortgage. The housing court judge (1) granted the defendants' motions as to landlord-tenant-related defenses and counterclaims, and (2) denied the defendants' motions as to the other defenses and counterclaims, including those challenging title. The Supreme Court affirmed, holding that the housing court has jurisdiction to hear defenses and counterclaims challenging the title of a plaintiff in a post-foreclosure summary process action and has the authority to award damages in conjunction with such counterclaims. View "Bank of Am., N.A. v. Rosa" on Justia Law

Petitioner was indicted on charges of murder, unlawful possession of a firearm, and attempted armed robbery, among other charges. The Commonwealth filed a motion for a protective order to limit the discovery of witnesses' identifying information. A judge allowed the motion in part, ordering that witnesses' addresses and telephone numbers not be disclosed to Petitioner. Petitioner filed this petition for review pursuant to Mass. Gen. Laws ch. 211,3 arguing that the order deprived him of his constitutional rights, including his ability to prepare a defense. A single justice denied relief. The Supreme Court affirmed, holding that Petitioner's issues could be adequately and effectively explored on direct appeal, if and when Petitioner was convicted. View "Madison v. Commonwealth" on Justia Law

John Doe, a female, pleaded guilty to several federal charges stemming from her prior management of an escort service, including sex trafficking of children. A hearing examiner of the Sex Offender Registry Board (SORB) classified Doe as a level one sex offender after determining that Doe presented a low risk of reoffense and attendant degree of dangerousness. The superior court affirmed SORB's classification determination of Doe as a level one sex offender. The Supreme Court vacated the judgment of the superior court and remanded the matter to SORB, holding (1) it was arbitrary and capricious for SORB to classify Doe's risk of reoffense and degree of dangerousness without considering the substantial evidence presented at the hearing regarding the effect of gender on recidivism; and (2) under the circumstances, the hearing examiner abused his discretion by denying Doe's motion for funds for an expert witness. View "Doe v. Sex Offender Registry Bd." on Justia Law

Plaintiff filed a consumer telephone service complaint against Verizon New England. The Department of Telecommunications and Cable eventually dismissed Plaintiff's claim as moot because, during the course of the proceedings, Plaintiff's customer relationship with Verizon had been terminated. On appeal, a single justice dismissed Plaintiff's complaint because it failed to comply with the timely filing requirements of Mass. Gen. Laws ch. 25, 5. Plaintiff appealed to the full court. The Department subsequently afforded Plaintiff a renewed opportunity to pursue a timely appeal under Mass. Gen. Laws ch. 25, 5, and Plaintiff chose to do so. The Supreme Court (1) affirmed the ruling of the single justice that Mass. Gen. Laws ch. 25, 5 governs appeals from final orders issued by the Department; and (2) declared the remainder of the matter moot because Plaintiff filed a new petition for judicial review within the time period required by Mass. Gen. Laws ch. 25, 5. Remanded. View "Olmstead v. Dep't of Telecommunications & Cable" on Justia Law