Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Constitutional Law

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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

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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

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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

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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

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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

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After a jury trial, Defendant was found guilty of murder in the first degree on theories of deliberate premeditation and extreme atrocity and cruelty. The Supreme Judicial Court affirmed the jury’s verdict, holding (1) the admission of testimony by a jailhouse informant did not violate Defendant’s confrontation rights; (2) a ballistics expert properly testified to a report prepared by an unavailable expert; (3) the admission of testimony of the Commonwealth’s wire expert created no substantial likelihood of a miscarriage of justice; (4) no reversible error occurred in the admission of two types of evidence resulting from searches of Defendant’s computer; and (5) the admission of transcript of the victim’s testimony from earlier proceedings involving both Defendant and the victim was not in error. View "Commonwealth v. Caruso" on Justia Law

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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

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The school zone statute punishes individuals who commit certain enumerated drug offenses within 300 feet of a school or 100 feet of a public park or playground. Defendant was a passenger in a motor vehicle that was driven on a public roadway past a public park and stopped at a red light. When the light turned green, law enforcement officers stopped the vehicle, at which point the vehicle was no longer within 100 feet of the public park. The officers searched the vehicle and found drugs and a firearm. Defendant was arrested and charged with a number of offenses, including committing a drug offense within one hundred feet of a public park, in violation of Mass. Gen. Laws ch. 94C, 32J. Defendant moved to dismiss the park zone charge, arguing that the school zone statute is unconstitutional as applied to him. The judge allowed the motion. The Supreme Court affirmed, holding that application of Mass. Gen. Laws ch. 94C, 32J to Defendant, under the facts and circumstances of this case, would be overreaching. View "Commonwealth v. Peterson" on Justia Law

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After a jury trial, Defendant was convicted of murder in the first degree on a theory of felony murder, armed home invasion, and armed assault with intent to rob. Defendant filed a motion for a new trial on the ground that the trial judge should have provided the jury with a felony murder merger instruction. The trial judge granted the motion as to the felony murder conviction but did not disturb Defendant’s remaining convictions. At Defendant’s retrial, a second jury found Defendant not guilty of the single charge of felony murder. In this appeal, Defendant argued, inter alia, that he cannot be guilty of his armed home invasion and armed assault with intent to rob convictions because the second jury acquitted him of felony murder predicated upon the same underlying felonies. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) the second trial cannot spare Defendant from the consequences of convictions properly decided by a different jury; and (2) Defendant’s claims of error in the first trial were unavailing. View "Commonwealth v. Resende" on Justia Law

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In 2002, Defendant pleaded guilty to indecent assault and battery. In 2013, Defendant filed a motion to withdraw his guilty plea or for a new trial, arguing that his plea counsel was constitutionally ineffective by advising Defendant that he would need to “register” if he pleaded guilty to a sex offense without explaining the consequences of sex offender registration. The motion judge denied the motion, concluding that Defendant failed to establish that plea counsel was constitutionally ineffective. The Supreme Judicial Court affirmed, holding that plea counsel was not constitutionally ineffective in giving this advice in 2002, and the question of whether such advice would be constitutionally ineffective based on the current statutory scheme for sex offender registration is best left for another day. View "Commonwealth v. Sylvester" on Justia Law