Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Criminal Law

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After a jury-waived trial, Defendant was convicted of one count of possession of child pornography with the intent to disseminate, one count of dissemination of child pornography, and three counts of possession of child pornography. Defendant appealed on three grounds. The Supreme Judicial Court affirmed, holding (1) the search warrant for the apartment in which Defendant was living was appropriately particularized; (2) the administrative subpoena that issued under Mass. Gen. Laws ch. 271, 17B for Internet service records was valid; and (3) the Commonwealth met the requirement of proving that Defendant had the lascivious intent necessary to support a conviction under Mass. Gen. Laws ch. 272, 29B. View "Commonwealth v. Molina" on Justia Law
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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

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Defendant was acquitted on a charge of receipt of stolen property and then prosecuted for larceny of the same property. Defendant argues that the subsequent larceny complaint was properly dismissed on the ground of double jeopardy. The court concluded that the same elements test, firmly rooted in the court's history and case law, is the only appropriate test to apply in both single and successive prosecution scenarios. The court explained that, because larceny and receipt are not the same offense for double jeopardy purposes, dismissal of the larceny complaint on double jeopardy grounds is not warranted. Finally, the court concluded that the successive prosecutions do not violate the equitable principles of due process, collateral estoppel, and judicial estoppel. Accordingly, the court reversed the allowance of defendant's motion to dismiss on the ground of double jeopardy. View "Commonwealth v. Rodriguez" 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 one of three occupants of a vehicle that was stopped for a traffic violation. When Defendant, the rear seat passenger, exited the vehicle based on an exit order, a police officer observed a handgun underneath his right thigh. At trial, the court ordered that evidence concerning the front seat passenger’s prior conviction of unlawful possession of a firearm was excluded for all purposes. Defense counsel violated this order and proceeded to elicit this testimony anyway. The judge declared a mistrial. Thereafter, Defendant moved to dismiss the charges on double jeopardy grounds, arguing that there had been no manifest necessity to declare a mistrial. A superior court judge denied the motion. Defendant then filed a petition pursuant to Mass. Gen. Laws ch. 211, 3. The single justice concluded that the trial judge had erred in determining that there was a manifest necessity to declare a mistrial. The Supreme Judicial Court remanded the matter to the county court for entry of an order denying Defendant’s petition, holding (1) there was no abuse of discretion in the judge’s decision to declare a mistrial on the ground of manifest necessity; and (2) the single justice applied a substituted judgment standard in finding otherwise. View "Commonwealth v. Bryan" 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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In Bridgeman v. District Attorney for the Suffolk District (Bridgeman I), the Supreme Judicial Court declined to accept a proposed “global remedy” of vacating the thousands of drug convictions affected by the misconduct of Annie Dookhan when she was employed as a chemist at the William A. Hinton State Laboratory Institute despite the claim that the time and expense of case-by-case adjudication had become untenable. Here, the district attorneys provided the single justice with lists identifying more than 20,000 potentially aggrieved defendants based on Dookhan’s misconduct. The single justice issued a reservation and report to the full court inviting it to reconsider its previous ruling. Rather than adopting Petitioners’ request for a global remedy, the Supreme Judicial Court adopted a new protocol for case-by-case adjudication. The adjudication will occur in three phases and be implemented by the single justice in the form of a declaratory judgment. View "Bridgeman v. District Attorney for the Suffolk District" 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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Defendant, an inmate, was charged with falsely reporting a sexual assault to a deputy sheriff employed at the corrections facility. After a jury-waived trial, Defendant was convicted of making a false report of a crime to a police officer. Defendant appealed, arguing that a deputy sheriff is not a police officer within the meaning of Mass. Gen. Laws ch. 269, 13A, and therefore, the evidence was insufficient to sustain the conviction. The Supreme Judicial Court reversed, holding that a deputy sheriff is not a “police officer” within the meaning of the statute. View "Commonwealth v. Gernrich" on Justia Law
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In 2012, the Boston Municipal Court issued a criminal complaint charging Defendant, who was mentally ill, with assault and battery by means of a dangerous weapon. Defendant has been in custody ever since, but each time the scheduled date approached, the trial was continued or else Defendant was found to be incompetent. Defendant unsuccessfully sought dismissal of the charge pursuant to Mass. Gen. Laws ch. 123, 16(f), under which a defendant who is found incompetent to stand trial is entitled to dismissal of the charge against him corresponding to one-half the maximum sentence the defendant could have received if convicted of the most serious crime with which he was charged. Defendant filed a petition for relief under Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court denied relief, holding (1) under section 16(f), the basis for the calculation of the date of dismissal is the maximum sentence provided for in the statute, regardless of the court in which the charges are pending; but (2) in this case, dismissal of the charge before the computed date may nevertheless be appropriate in the interest of justice. Remanded. View "Commonwealth v. Calvaire" on Justia Law
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