Justia Massachusetts Supreme Court Opinion Summaries

Twenty-three years after a young woman was found dead in a vacant lot, DNA was extracted from samples taken from the victim’s body and clothing. A match was found with Defendant’s DNA. After a jury trial, Defendant was found guilty of murder in the first degree. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to support the verdict; (2) the trial judge’s exclusion of evidence proffered by Defendant as third-party culprit evidence and Bowden evidence was not in error; (3) comments made by the prosecutor during closing argument were misguided, but there was no substantial likelihood that a miscarriage of justice occurred; and (4) the trial judge did not err in his instructions to the reconstituted jury after an original deliberating juror had been discharged. View "Commonwealth v. Scott" on Justia Law

The two defendants in this case were both convicted of criminal harassment for posting information about the victims online along with false statements about items that the victims allegedly had for sale or were giving away solely for the purpose of encouraging unwitting third parties to repeatedly contact and harass the victims, and for sending hostile communications to the victims. On appeal, Defendants challenged the constitutionality of the criminal harassment statute, both facial and as applied to them. The Supreme Judicial Court affirmed, holding (1) the criminal harassment statute is neither unconstitutionally overbroad nor vague; (2) Defendants’ as-applied constitutional challenge failed because the conduct in question was not protected speech but, rather, a hybrid of conduct and speech integral to the commission of a crime; and (3) Defendants’ remaining claims similarly failed. View "Commonwealth v. Johnson" on Justia Law

This case arose from a longtime dispute between Dewoe Smallwood and his former girlfriend concerning ownership of certain real property. In 1997, Smallwood’s former girlfriend commenced a civil action against Smallwood, culminating in the sale of the property. After a final judgment was entered, Smallwood commenced this action seeking extraordinary relief pursuant to Mass. Gen. Laws ch. 211, 3. Smallwood recounted numerous rulings that the superior court judges had made against him in the underlying action and asserted that he had filed complaints against certain judges who had made those adverse rulings, to no avail. A single justice of the Supreme Judicial Court denied relief. The Supreme Judicial Court affirmed, holding that the single justice did not err in dismissing Smallwood’s petition under chapter 211, section 3. View "In re Petition of Smallwood" on Justia Law

Haywood Bledsoe, an inmate in the custody of the Department of Correction, commenced an action against the Commissioner of Correction and other officials. A judge granted summary judgment as to some of the counts in Bledsoe’s complaint, and after a hearing in which Bledsoe participated by video conference, another judge granted summary judgment on the remaining counts. While Bledsoe’s appeal was pending, he requested, without success, a transcript of the summary judgment hearing. Bledsoe then moved for a DVD record of the hearing at his own expense. The motion was denied on the ground that it was not necessary for the appeal. Bledsoe filed a petition for relief under Mass. Gen. Laws ch. 211, 3 from the denial of that motion. A single justice of the Supreme Judicial Court denied the petition. The Supreme Judicial Court affirmed, holding that Bledsoe was not entitled to extraordinary relief under the Court’s general superintendence power. View "Bledsoe v. Comm’r of Corr." on Justia Law

In 2011, in response to an increased number of foreclosures, the City of Springfield enacted two ordinances addressing properties left vacant during or after the foreclosure process. The mediation ordinance established a program requiring mandatory mediation between mortgagors and mortgagees. The foreclosure ordinance required owners of buildings that are vacant or undergoing foreclosure to register with the City. Six banks holding mortgage notes on properties in the City (Plaintiffs) filed suit seeking declaratory and injunctive relief from the enforcement of the ordinances. The federal district court allowed the City’s motion for summary judgment. Plaintiffs appealed, and the First Circuit certified two questions to the Supreme Judicial Court. The Court answered (1) the foreclosure statute preempts the mediation ordinance in whole but does not preempt the foreclosure ordinance; (2) the foreclosure ordinance is preempted by the Massachusetts Oil and Hazardous Material Release Prevention Act and the state sanitary code; and (3) the foreclosure ordinance does not impose an unlawful tax in violation of the Constitution of the Commonwealth of Massachusetts. View "Easthampton Savings Bank v. City of Springfield" on Justia Law

Following 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. The Appeals Court affirmed. At issue on appeal was whether Defendant received notice of the suspension of his license. The Supreme Judicial Court reversed the judgment, holding that the record contained no evidence demonstrating that Defendant was notified of the license suspension - and actually contained some evidence suggesting the contrary - and therefore, the Commonwealth did not meet its burden of proving beyond a reasonable doubt every element of the offense. View "Commonwealth v. Oyewole" on Justia Law

The Department of Children and Families filed a petition for the care and protection of Quan, who was one year old. Mother and Father stipulated to the entry of decrees adjudicating Quan to be in need of care and protection, committing him to the custody of the Department, and terminating their parental rights. The judge accepted the stipulations and entered final decrees terminating the parents’ parental rights. Approximately nine months later the parents moved for relief from the final decrees. A juvenile court judge vacated the decrees terminating the parents’ parental rights on the ground that there had been a material mistake of law or neglect. The Supreme Judicial Court affirmed the order granting the parents’ motions for relief from the final decrees terminating their parental rights, holding that without a record of what transpired at the colloquies conducted before the judge accepted the stipulations, it could not be said that the motion judge’s findings were supported by or contrary to the evidence. View "In re Adoption of Quan" on Justia Law

Defendant was convicted on seventeen indictments, including three counts of aggravated burglary. Two of those counts arose from the burglary of a dwelling in Agawam involving two assaults therein, and the third count arose from a break into a home in Springfield and an assault on one of its residents. Defendant filed a motion for postconviction relief seeking to correct illegal sentences, arguing (1) the two Agawan indictments were duplicative, and (2) an amendment to the Springfield indictment as to the person assaulted rendered that conviction unconstitutional. The Supreme Judicial Court reversed in part and affirmed in part, holding (1) Mass. Gen. Laws ch. 266, 14 permits only one burglary conviction per dwelling, and therefore, Defendant’s conviction on the duplicative indictment must be vacated; and (2) the name of the person assaulted was not an essential element to the crime charged in this case, and therefore, the conviction on the amended Springfield indictment was constitutional. View "Commonwealth v. Bolden" on Justia Law

After a jury trial, Defendant was convicted of murder in the second degree and other crimes. The trial judge denied Defendant’s motion for a new trial. The Supreme Judicial Court affirmed, holding (1) Defendant was not denied the effective assistance of counsel because of his attorney’s failure to object to the in-court identification of Defendant by an eyewitness and because of his attorney’s failure to object to the enforcement of a sequestration order during jury selection; (2) the trial judge did not err in denying Defendant’s motion for a new trial on the basis of prosecutorial misconduct; (3) the trial judge did not err in admitting cellular telephone records where the records were obtained by court order rather than with a search warrant; and (4) Defendant’s constitutional rights were not violated by his conviction of possession of an unlicensed firearm where Commonwealth didn’t prove that Defendant lacked a license to carry firearms. View "Commonwealth v. Collins" on Justia Law

In this case, the Supreme Judicial Court established a new standard for the admission of in-court identifications where the eyewitness had not previously participated in an out-of-court identification procedure. After a jury trial, Defendant was convicted on two indictments of possession of child pornography. The Supreme Judicial Court vacated the convictions, holding (1) under the new standard articulated today, the in-court identifications in this case could not have been admissible; (2) the trial judge erred in excluding from evidence Defendant’s denial to the police of having used library computers to view child pornography and in admitting into evidence three pornographic drawings of children found in Defendant’s possession; and (3) the admission of the in-court identifications and the trial errors resulted in unfair prejudice that required a new trial. View "Commonwealth v. Crayton" on Justia Law