Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Civil Rights

By
Police made two warrantless entries into Defendant’s apartment after receiving reports that it smelled like drugs. Based on observations of drug activity, the policy obtained a warrant. Thereafter, Defendant was arrested and charged with drug offenses. The trial judge granted Defendant’s motions to suppress (1) the evidence seized during the execution of the search warrant, concluding that no emergency justified the warrantless entries, without which the Commonwealth could not establish he probable cause necessary for the subsequent warrant, and (2) statements Defendant made to police following his arrest, concluding that the statements were the fruit of Defendant’s unlawful arrest. The Supreme Judicial Court affirmed, holding (1) the warrantless entries were unlawful; and (2) the Commonwealth did not meet its burden of showing that Defendant’s statements were sufficiently attenuated from the Commonwealth’s unlawful conduct. View "Commonwealth v. Tuschall" on Justia Law

By
After a jury trial, Defendant was found guilty of murder in the first degree on a theory of deliberate premeditation. Defendant appealed from his convictions and from the trial court’s denial of his motion for a new trial, arguing, inter alia, that the motion judge erred in denying his pretrial motion to suppress the testimony of a key prosecution witness because the Commonwealth had obtained his testimony as a result of an illegal wiretap that was previously ordered suppressed. The Supreme Judicial Court affirmed and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E, holding (1) the motion judge did not err in determining that the witness’s testimony was sufficiently attenuated from the suppressed wiretap evidence to dissipate the taint of illegality; and (2) trial counsel provided constitutionally effective assistance. View "Commonwealth v. Long" on Justia Law

By
Defendants, Charles Mendez and Tacuma Massie, were convicted of murder in the first degree, armed robbery, and other offenses. Both defendants were charged on a theory of felony murder. Each defendant filed a timely notice of appeal. The Supreme Judicial Court affirmed Defendants’ convictions and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial court did not err in denying Defendants’ motions to suppress evidence seized as a result of a warrantless stop that took place soon after the shooting; (2) the motion judge did not err in deciding to join for trial certain charges; (3) two aspects of the prosecutor’s closing argument challenged by Defendants were not error; (4) there was sufficient evidence to convict Massie of the armed robbery and felony murder; and (5) Defendants’ Moffett claims were unavailing. View "Commonwealth v. Mendez" on Justia Law

By
After a jury trial, Defendant was convicted of possessing child pornography. Defendant appealed, arguing that the district court erred in denying his motion to suppress computer evidence obtained pursuant to a search warrant issued for the the place searched because the police needed more information to link Defendant to the place searched and the items seized. The Supreme Judicial Court affirmed, holding that there was a substantial basis from which to conclude that the evidence of downloading and sharing child pornography via the Internet was probably present at the place to be searched. View "Commonwealth v. Martinez" on Justia Law

By
After a jury trial, Appellant was convicted of two counts of unlawful possession of a loaded firearm and one count of possession of a firearm without a license. Appellant appealed, arguing that the Commonwealth failed to demonstrate that the police had reasonable suspicion to conduct an investigatory stop of his vehicle, and therefore, the trial court erred in denying his motion to suppress. The Court of Appeals agreed with Appellant and reversed the judgments of conviction, the verdicts, and the motion to suppress, holding that the police did not have reasonable suspicion to conduct the investigatory stop. View "Commonwealth v. Pinto" on Justia Law

By
Defendant was indicted for multiple firearms offenses, among other offenses. Defendant moved to suppress evidence seized during the search of a motor vehicle he had been driving. A superior court judge allowed the motion, concluding that, at the time a police officer stopped and seized the vehicle, the officer lacked a reasonable, articulable suspicion that criminal activity was afoot. The Supreme Judicial Court reversed the motion judge’s order allowing the motion to suppress, holding (1) the investigatory stop was predicated on reasonable suspicion of criminal activity; and (2) the officer’s actions were “reasonably related in scope to the circumstances which justified the interference in the first place.” View "Commonwealth v. Edwards" on Justia Law

By
After a jury-waived trial, Defendant was convicted of various firearm charges. On appeal, Defendant challenged the denial of his motion to suppress the firearm, asserting that police officers lacked reasonable suspicion to stop him to investigate a report of shots fired at a vehicle. The Appeals Court affirmed. The Supreme Judicial court vacated the conviction and remanded for a new trial, holding that the motion judge erred in denying the motion to suppress because, assessing the totality of the circumstances leading to the stop of Defendant, the facts known to the police at the time of the seizure were not sufficient to establish reasonable suspicion that Defendant was connected to the alleged shooting at the vehicle. View "Commonwealth v. Meneus" on Justia Law

By
Defendant was charged with murder in the first degree. Defendant filed a motion to suppress statements he made at two police stations, arguing that he did not knowingly and intelligently waive his Miranda rights and that the statements were not made voluntarily. Defendant then moved to impound a video recording and transcript of a police interview with Defendant that was the subject of the motion to suppress and that was subsequently suppressed. A superior court judge orally denied the motion to impound. A single justice of the Appeals Court denied Defendant’s request for interlocutory relief. A single justice of the Supreme Judicial Court vacated the denial of the motion to impound, concluding that the single justice committed an error of law and abused his discretion in affirming the judge’s denial of the motion to impound. The Supreme Judicial Court affirmed the motion judge's denial of the motion to impound, holding (1) the motion judge applied the correct legal standard in deciding Defendant’s motion to impound; and (2) the motion judge did not abuse his discretion in denying the motion to impound. View "Commonwealth v. Chism" on Justia Law

By
Defendant was stopped for failing to stop at a stop sign. The officer concluded that Defendant was using the vehicle without authority and decided to impound the vehicle. During an inventory search in preparation for impoundment, the officer seized a handgun and box of ammunition from the vehicle. Defendant was charged with unlawful possession of a firearm, unlawful possession of a loaded firearm, unlawful possession of ammunition without a firearm identification card, and unauthorized use of a motor vehicle. Defendant filed a motion to suppress the handgun, the ammunition, and statements he made to police. The municipal court allowed the motion to suppress. The Supreme Judicial Court affirmed the order allowing the motion to suppress, holding (1) the police did not have probable cause to believe that Defendant was operating the vehicle he was driving in violation of Mass. Gen. Laws ch. 90, 24(2)(a), and therefore, the impoundment of the vehicle was not proper; and (2) therefore, the inventory search was not lawful, and the handgun and ammunition were properly suppressed. View "Commonwealth v. Campbell" on Justia Law

By
Defendant was charged with murder in the first degree. A superior court judge allowed Defendant’s motion to suppress evidence recovered from his cellular telephone, concluding that the seizure of the telephone was not supported by probable cause. The Supreme Judicial Court affirmed, holding (1) probable cause to search or seize a person’s cellular telephone may not be based solely on an officer’s opinion or belief that the device is likely to contain evidence of the crime under investigation; (2) because the officers in this case lacked any information establishing the existence of relevant evidence likely to be found on Defendant’s telephone, the seizure was not supported by probable cause; and (3) the Commonwealth did not meet its burden of demonstrating that the sixty-eight-day-delay between the seizure and the application for a search warrant was reasonable. View "Commonwealth v. White" on Justia Law