Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Constitutional Law

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Plaintiff, a Massachusetts prison inmate, brought civil rights action claiming that Defendants violated his constitutional right to due process by holding him in a special management unit (SMU) - or solitary confinement - for ten months without a hearing while waiting to reclassify or transfer him. The Supreme Judicial Court held that segregated confinement on awaiting action status for longer than ninety days gives rise to a liberty interest entitling an inmate to notice and a hearing. On remand, the superior court entered declaratory judgment in favor of Plaintiff and awarded him attorney’s fees and costs. Defendants appealed, arguing that Plaintiff was not a prevailing party under 42 U.S.C. § 1988(b) because he had been discharged from SMU detention long before he won any relief, and therefore, the declaratory judgment was moot and did not directly benefit him or materially alter his relationship with Defendants. The Supreme Judicial Court affirmed, holding (1) Plaintiff did qualify as a prevailing party in the circumstances of this case; and (2) the award of fees to Plaintiff was reasonable. View "LaChance v. Commissioner of Correction" on Justia Law

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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

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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

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After a jury trial, Defendant was convicted of two counts of criminal harassment. The convictions were based on five letters that Defendant wrote and sent to Michael and Susan Costello after a local election in which Michael had been elected as a town selectman. The Supreme Court reversed and dismissed Defendant’s conviction of criminal harassment of Michael and vacated Defendant’s conviction of criminal harassment of Susan and remanded for a new trial on that count, holding (1) in light of First Amendment constitutional protections afforded to political speech and the lack of evidence of serious alarm of Michael’s part, the evidence was not sufficient to support Defendant’s conviction of criminal harassment of Michael; and (2) the speech on which the complaint of criminal harassment of Susan is premised might be found to qualify as fitting within a constitutionally unprotected category of speech that may be subject to prosecution as a form of criminal harassment. View "Commonwealth v. Bigelow" on Justia Law

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After a jury-waived trial, Defendant was convicted of unlawful possession of a firearm. Defendant appealed the denial of his motion to suppress a firearm and statements he made after his arrest, arguing that the police lacked reasonable suspicion to make an investigatory stop of him in connection with a breaking and entering that had occurred in a nearby home approximately thirty minutes earlier. The Appeals Court affirmed. The Supreme Judicial Court vacated the conviction, holding that the trial court erred in denying Defendant’s motion to suppress because the police lacked reasonable suspicion for the investigatory stop. Remanded. View "Commonwealth v. Warren" on Justia Law

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After a jury trial, Defendant was convicted of operating a motor vehicle while under the influence of intoxicating liquor. The Supreme Judicial Court affirmed the conviction, holding (1) the trial court did not err in admitting evidence of Defendant’s failure to properly perform a breathalyzer test after giving consent, as the evidence was not inadmissible as refusal evidence; (2) the admission of the police-appointed interpreter’s English language version of Defendant’s statements did not violate the rule against hearsay, as the interpreter acted as Defendant’s agent under the circumstances of this case; (3) Defendant’s unpreserved confrontation claim was unavailing; (4) the evidence was sufficient to establish Defendant’s impairment; and (5) there was no prejudicial error in the jury instructions. View "Commonwealth v. Adonsoto" on Justia Law

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The City of Springfield filed suit against the City of Papillion, and Sarpy County, seeking to enjoin Papillion from annexing land which had been indicated as Springfield’s area of future growth in a map adopted by the County in 1995. The district court for Sarpy County found that Springfield lacked standing; Springfield appealed. After review, the Nebraska Supreme Court found that Springfield asserted an infringement of its statutory governmental functions and rights under the County Industrial Sewer Construction Act. That infringement was sufficient to grant standing. The Court reversed the district court and remanded the case for further proceedings. View "Massachusetts v. Herndon" on Justia Law

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Petitioners, Timothy Deal, Siegfried Golston, and Jeffrey Roberio, were juvenile homicide offenders serving mandatory indeterminate life sentences, and who had a constitutional right to a "meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation." At issue in this case was the manner in which juvenile homicide offenders were classified and placed in Department of Correction (department) facilities. Specifically, the issue was whether the department's practice of using "discretionary override codes" to block qualifying juvenile homicide offenders from placement in a minimum security facility unless and until the individual received a positive parole vote violated: (1) G. L. c. 119, section 72B (as amended by St. 2014, c. 189, section 2); or (2) their right to a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation under the Eighth and Fourteenth Amendments to the United States Constitution, arts. 12 and 26 of the Massachusetts Declaration of Rights, or both Constitutions. After review, the Supreme Court concluded that the department's current classification practice violated G. L. c. 119, section 72B, because the department's failure to consider a juvenile homicide offender's suitability for minimum security classification on a case-by-case basis amounted to a categorical bar as proscribed by the statute. Furthermore, the Court concluded that the department's practice did not violate petitioners' constitutional right to a meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation because there was no constitutionally protected expectation that a juvenile homicide offender would be released to the community after serving a statutorily prescribed portion of his sentence. View "Deal v. Comm'r of Correction" on Justia Law

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Defendant was arrested for operating while under the influence of intoxicating liquor. Defendant was not given an opportunity to consult with counsel before being required to decide whether to submit to a breathalyzer test. Defendant moved to suppress the results of the breathalyzer test, arguing that she had a right to counsel before deciding whether to submit to the breathalyzer test. After an evidentiary hearing, the district court reported a question of law asking whether the 2003 amendment to Mass. Gen. Laws ch. 90, 24, the statute establishing the offense of driving while under the influence of intoxicating liquor, now makes the decision by a defendant whether or not to take a breath test is a critical stage of the criminal proceedings requiring that the defendant be advised of his or her right to counsel prior to making that decision. The Supreme Judicial Court answered the reported question in the negative, holding that there is no right to counsel under the Sixth Amendment to the United States Constitution or article 12 of the Massachusetts Declaration of Rights before a defendant decides whether to submit to a breathalyzer test. View "Commonwealth v. Neary-French" on Justia Law

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Petitioner was convicted of murder in the first degree. Petitioner was a juvenile when the crime was committed. Thirty years later, the Supreme Judicial Court determined that any juvenile offender who had been convicted of murder in the first degree and sentenced to life in prison without the possibility of parole became eligible for parole within sixty days before the expiration of fifteen years of his life sentence. Therefore, Petitioner became immediately eligible to be considered for parole. Four out of seven members of the parole board panel voted in favor of parole. The parole board refused to grant a parole permit because, pursuant to a 2012 amendment to Mass. Gen. Laws ch. 127, 133A, a parole permit can only be granted by a vote of two-thirds of the parole board members on the panel. Petitioner appealed, arguing that the application of the amendment to his parole determination, rather than the version in effect at the time he committed the crime, was an ex post facto violation. The Supreme Judicial Court reversed the parole board’s decision, holding (1) the supermajority amendment was applied retroactively to Petitioner; and (2) the amendment was, as applied to Petitioner, an ex post facto violation. View "Clay v. Massachusetts Parole Board" on Justia Law