Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. On appeal, Defendant conceded that the evidence was sufficient to support the jury’s verdict and did not argue that any error occurred at trial. Rather, Defendant argued that the verdict was against the weight of the evidence where considerable evidence suggested that he acted in self-defense and also pointed to mitigation based on heat of passion. The Supreme Court affirmed, holding that Defendant’s trial was conducted fairly and without error, and there was no reason to reduce Defendant’s conviction to a lesser degree of guilt or to order a new trial. View "Commonwealth v. Ortiz" on Justia Law

Defendant, who was in the business of collecting and selling scrap metal, was convicted of larceny under $250 in connection with his removal of steel pipe from a construction site located on private property. Defendant claimed as an affirmative defense at trial that he lacked the requisite intent to steal because he honestly but mistakenly believed that the property he removed from the site was abandoned. The trial judge viewed the affirmative defense as requiring proof that Defendant’s belief was objectively reasonable. The Supreme Judicial Court vacated the conviction and remanded for a new trial, holding (1) an honest belief need not be objectively reasonable to negate the specific intent required for larceny; and (2) Defendant adequately raised the defense of honest belief that the items he took were abandoned, and it was the Commonwealth’s burden to prove beyond a reasonable doubt that Defendant’s subjective belief was not honestly held but, instead, was a pretense. View "Commonwealth v. Liebenow" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. Defendant appealed, arguing that the trial court erred in denying his motion to suppress a surreptitiously recorded oral conversation between him and a police informant, that evidence of the conversation should have been excluded at trial, and therefore, that his conviction must be reversed. At issue before the Supreme Court was whether the one-party consent exception to the statutory prohibition against the secret recording or oral communications applied in this case. The Supreme Court reversed Defendant’s conviction, holding that the recorded conversation did not fit within the exception, that the conversation should not have been admitted in evidence at trial, and that the error was not harmless. View "Commonwealth v. Burgos" on Justia Law

Plaintiff filed an action against his former employer, the Attleboro Housing Authority (AHA), for alleged violations of the Wage Act, claiming (1) the AHA intentionally misclassified his position, thereby failing to pay him the wages to which he was entitled; and (2) the AHA terminated him in retaliation for complaining about the nonpayment of earned wages. The jury rendered a verdict in favor of Plaintiff on both claims and awarded damages against the AHA. The parties then filed numerous posttrial motions, to no avail. The Supreme Judicial Court affirmed, holding (1) the superior court had subject matter jurisdiction over Plaintiff’s claims under the Wage Act; (2) reinstatement to employment is not an available remedy for violations of the Wage Act; and (3) the trial judge did not abuse his discretion in denying Plaintiff’s motion for a new trial on damages or, in the alternative, for additur. View "Fernandes v. Attleboro Housing Auth." on Justia Law

Following a jury trial, Defendant was convicted of distributing cocaine and doing so in a school zone. Defendant appealed. While the appeal was pending, the school zone statute was amended to reduce the radius of the school zone. The appeals court affirmed Defendant’s convictions, concluding that the amendment did not have retroactive effect. The Supreme Judicial Court affirmed, holding that the Legislature did not intend to grant new trials to defendants who already had been convicted after the effective date of the amendment, and therefore, the amendment did not entitle Defendant to a new trial on his conviction of a school zone violation. View "Commonwealth v. Thompson" on Justia Law

John Doe, who was thirty-one years old, pleaded guilty to several sex offenses that he committed when he was a juvenile. Seven years later, Doe was classified as a level one sex offender. The classification was upheld by a judge of the superior court. Doe appealed, arguing that he should not be required to register as a sex offender in light of scientific research showing that adolescent brains are different from adult brains and in light of the long period of time that had elapsed since his last offense. The Supreme Court affirmed the superior court judge’s decision upholding the hearing examiner’s classification determination, holding that the hearing examiner’s decision was supported by substantial evidence. View "Doe v. Sex Offender Registry Bd." on Justia Law

After a jury trial, Defendant was convicted of deliberately premeditated murder and possession of a class B substance. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) there was no error in the denial of Defendant’s motion for a required finding of not guilty, as the evidence was sufficient to support a conviction of deliberately premeditated murder; (2) the trial court did not err in Defendant’s motion to dismiss based on Mass. R. Crim. P. 36, as amended, for the alleged denial of Defendant’s right to a speedy trial; (3) there was no error in the denial of Defendant’s motion to dismiss for belated discovery disclosure; (4) the trial judge did not err in failing to declare, sua sponte, a mistrial based on alleged jury tampering; and (5) there was no error in the judge’s instruction concerning the manner in which the jury should consider the testimony of a cooperating witness. View "Commonwealth v. Roman" on Justia Law