Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law

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Police officers recovered a loaded firearm from a motor vehicle after impounding and conducting an inventory search of the vehicle. Defendant was subsequently charged with carrying a firearm without a license and possession of a firearm or ammunition without a firearm identification card. Defendant filed a motion to suppress, arguing that the officers’ decision to impound and inventory the motor vehicle was not reasonable. A district court judge allowed the motion to suppress, concluding that impoundment was improper based on its findings that the vehicle was not in danger of damage or theft. The Supreme Judicial Court affirmed the order allowing the motion to suppress, holding that it was not reasonable for the police to impound the vehicle for the purpose of protecting it from theft or vandalism, and impoundment was not warranted to protect the public. View "Commonwealth v. Crowley-Chester" on Justia 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 convicted of three counts of assault and battery and one count of kidnapping. The conviction arose out of an incident of domestic violence. The Supreme Judicial Court affirmed, holding (1) the trial judge did not abuse his broad discretion in finding an impermissible pattern at the point he rejected Defendant’s peremptory challenge to a certain female juror; (2) the trial judge did not err in admitting evidence of a prior incident of alleged domestic violence between Defendant and the victim; and (3) there was sufficient evidence to support Defendant’s kidnapping conviction. View "Commonwealth v. Oberle" on Justia Law
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After a jury trial, Defendant was convicted of murder in the second degree and carrying a firearm without a license. On appeal, Defendant argued, in part, that the trial judge erred in denying his motion for a mistrial on the ground that, during the jury’s deliberations, the jurors were exposed to extraneous materials and materials that had been excluded as evidence at trial. The Appeals Court rejected Defendant’s claims of error and affirmed the convictions. The Supreme Judicial Court affirmed, holding that the trial judge did not abuse her discretion in declining to declare a mistrial as a result of the jury’s exposure to the materials at issue during deliberations and in handling the circumstance as she did. View "Commonwealth v. Blanchard" 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-waived trial, Defendant was found guilty of breaking and entering in the daytime with the intent to commit a felony and larceny of property over $250. Defendant’s fingerprint at the crime scene constituted the only identification evidence. On appeal, Defendant argued that the evidence was insufficient to support the convictions. The Appeals Court affirmed. The Supreme Judicial Court reversed, holding that the evidence was not sufficient to find, beyond a reasonable doubt, that Defendant left his fingerprint at the time of the break-in, and therefore, there was insufficient evidence to support the convictions. View "Commonwealth v. French" on Justia Law
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A grand jury returned indictments against Defendant on various charges, including three counts of armed assault with intent to murder and murder in the second degree. Defendant moved to suppress the identification of him by an eyewitness, Brianna Johnson, and also moved to suppress Johnson’s identification of a firearm as the one used by Defendant in the commission of the crime. The motion judge denied the motion to suppress the identification of Defendant but allowed the motion to suppress the identification of the firearm. The Supreme Judicial Court affirmed, holding (1) under the circumstances of this case, the failure to detectives showing a photographic array to the eyewitness to use the protocol outlined in Commonwealth v. Silva-Santiago did not warrant suppression of Defendant’s identification of Defendant; (2) the use of a simultaneous rather than a sequential display of photographs in an array was not unnecessarily suggestive; and (3) the motion judge did not abuse his discretion in ruling the identification of the firearm as inadmissible under the common law of evidence due to suggestive police questioning and subsequent police confirmation. View "Commonwealth v. Thomas" on Justia Law
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Defendant was charged with disorderly conduct. The charge arose from Defendant’s behavior as a patient in the psychiatric area of the emergency department at a Boston hospital. Defendant appealed, arguing that there was insufficient evidence to support his conviction. The Supreme Judicial Court reversed Defendant’s conviction, vacated the judgment, and remanded to the municipal court for entry of a judgment of dismissal, holding that the evidence was not sufficient to permit a reasonable jury to find beyond a reasonable doubt that Defendant consciously disregarded a “substantial and unjustifiable risk of public inconvenience, annoyance, or alarm.” View "Commonwealth v. Accime" on Justia Law
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After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. The Supreme Judicial Court affirmed Defendant’s convictions and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not err by permitting the Commonwealth’s expert witness to opine that Defendant’s behavior was planned and goal-directed; (2) the trial judge did not erroneously permit the same expert to state the bases of her opinion on direct examination; and (3) the prosecutor did not make statements not supported by the evidence during closing arguments. View "Commonwealth v. Goddard" on Justia Law
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