Justia Massachusetts Supreme Court Opinion Summaries

The case involves a probationer who was arrested during a traffic stop and subsequently charged with possession of cocaine with intent to distribute and unlawful possession of a firearm. During the traffic stop, a state trooper observed the vehicle speeding and making unsafe lane changes. Upon stopping the vehicle, the trooper noticed suspicious behavior from the back seat passenger and found drugs and a firearm in the vehicle. The probationer was found to have thrown a bag containing drugs to the back seat passenger as the vehicle was being pulled over.The Superior Court judge found the probationer in violation of his probation conditions, revoked his probation, and sentenced him to state prison. The probationer appealed, arguing that the evidence was insufficient to prove he possessed cocaine with intent to distribute and unlawfully possessed a firearm. He also claimed ineffective assistance of counsel for not moving to suppress the evidence on equal protection grounds, alleging racial animosity by the state trooper.The Supreme Judicial Court of Massachusetts reviewed the case and upheld the lower court's decision. The court found sufficient evidence to support the probation violation, including the possession and intent to distribute cocaine and the unlawful possession of a firearm. The court also rejected the claim of ineffective assistance of counsel, stating that the exclusionary rule does not generally apply to probation revocation proceedings and that the counsel's performance did not fall below the standard of an ordinary fallible lawyer.The court affirmed the revocation of probation and the denial of the motion for a new hearing. View "Commonwealth v. Gelin" on Justia Law

The defendant was involved in a kidnapping scheme orchestrated by James Feeney, who sought revenge against the victim, James Robertson, due to a romantic rivalry. Feeney enlisted the help of his cousin Alfred Ricci and the defendant, who was Feeney's car mechanic. Disguised as probation officers, the defendant and Ricci went to the victim's home, falsely claimed they were taking him for a random drug test, and brought him to Ricci's garage where Feeney was waiting. The victim was restrained in a metal chair bolted to the floor. Feeney later inflicted serious bodily injury on the victim, who was eventually found dead.The defendant was indicted for kidnapping, conspiracy, murder, and aggravated kidnapping. At trial, the judge denied the defendant's motion for a required finding of not guilty on the aggravated kidnapping charge. The jury found the defendant guilty of involuntary manslaughter, conspiracy to kidnap, and aggravated kidnapping. The defendant was sentenced to 25-30 years for aggravated kidnapping, with concurrent sentences for manslaughter and conspiracy. The Appeals Court affirmed the conviction, but a dissenting opinion argued that the rule of lenity should apply due to ambiguity in the statute.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the statute requires the dangerous weapon to be used to inflict serious bodily injury. The court found that the jury instructions were erroneous and prejudicial, as they allowed for a conviction without proving the weapon was used to inflict injury. The court vacated the defendant's conviction of aggravated kidnapping and remanded the case for further proceedings, allowing the Commonwealth to either move for sentencing on the lesser included offense of kidnapping or retry the defendant on the aggravated kidnapping charge. View "Commonwealth v. Morrison" on Justia Law

The defendant is alleged to have raped eight women by luring heavily intoxicated women into his vehicle under the guise of being a rideshare operator, then raping them after they passed out, often recording the assaults. He was indicted on multiple charges across three separate dockets in the Superior Court, including aggravated rape, indecent assault and battery, kidnapping, and photographing an unsuspecting nude person. Initially, cash bail was set, but later increased. The Commonwealth moved for pretrial detention based on dangerousness under General Laws c. 276, § 58A, which was granted after hearings.The defendant filed several motions for bail review and reconsideration of his pretrial detention, all of which were denied by the Superior Court. The motion judge concluded that rape qualifies as a predicate offense under the force clause of § 58A because it involves the use of force. The defendant then appealed to the Supreme Judicial Court for Suffolk County, arguing that rape should not be considered a predicate offense under § 58A and that the evidence did not warrant his detention.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The court held that rape, as defined under G. L. c. 265, § 22, qualifies as a predicate offense under the force clause of § 58A because it inherently involves physical force. The court distinguished rape from other offenses like indecent assault and battery and statutory rape, which do not necessarily involve physical force. The court emphasized that the act of forced penetration, regardless of the victim's capacity to consent, constitutes physical force sufficient to meet the requirements of § 58A. The judgment of the single justice denying the defendant's emergency petition for relief was affirmed. View "Campbell v. Commonwealth" on Justia Law

The defendant was convicted of sexual offenses against two minor girls, Kathy and Denise, who lived with him at the time of the alleged abuse. Kathy testified that the defendant touched her inappropriately on multiple occasions, including an incident where he allegedly penetrated her. Denise testified that the defendant sexually abused her in various ways, including touching and penetrating her. The defendant sought to introduce evidence of Denise's prior allegations of sexual abuse by a third party, arguing that the similarities between those allegations and her allegations against him suggested fabrication.The Superior Court judge excluded evidence of Denise's prior allegations under the rape shield statute, which generally bars evidence of a victim's past sexual conduct. The judge also prohibited cross-examination on this topic, reasoning that the evidence did not fall within any exceptions to the statute and that the policy of protecting victims, especially children, favored exclusion. The jury convicted the defendant on several charges, but acquitted him on others. The Appeals Court affirmed the convictions, and the defendant sought further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and held that the trial judge erred in excluding evidence of Denise's prior allegations of sexual abuse. The court found that the rape shield statute did apply to the evidence in question but concluded that the exclusion violated the defendant's constitutional rights to confront witnesses and present a complete defense. The court determined that the similarities between Denise's allegations against the defendant and her prior allegations were significant enough to warrant cross-examination. The court reversed the convictions and remanded the case for a new trial, emphasizing that the error was not harmless beyond a reasonable doubt given the centrality of Denise's testimony to the prosecution's case. View "Commonwealth v. Jacques" on Justia Law

The defendant was convicted of sexual offenses against his granddaughter and sentenced to state prison followed by five years of supervised probation. The probation conditions included GPS monitoring and a requirement to stay away from the victim and her family. After his release, the defendant moved to vacate the GPS condition, arguing it was unconstitutional without an individualized determination of its reasonableness, as required by a recent court decision.The Superior Court judge denied the motion, finding the GPS condition reasonable and added exclusion zones for the cities of Framingham and Marlborough, which were not specified in the original sentence. The defendant appealed, arguing that the GPS condition was unreasonable and that adding exclusion zones violated double jeopardy principles.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the addition of exclusion zones did not violate double jeopardy because the original sentence contemplated such zones. However, the court found that the scope of the exclusion zones, covering entire cities, was overly broad and increased the severity of the defendant's sentence. The court affirmed the GPS condition as reasonable, given the seriousness of the offense and the defendant's moderate risk of reoffense, but remanded for revision of the exclusion zones to be consistent with statutory and probationary goals.The court also directed the probation department to remove GPS monitors from defendants who had not received a reasonableness hearing and to refrain from attaching monitors until such hearings are held, ensuring compliance with constitutional requirements. View "Commonwealth v. Rodriguez" on Justia Law

The defendant was convicted of first-degree murder on a felony-murder theory, with armed robbery as the predicate offense. The victim, who sold drugs from her apartment, was found stabbed to death. The defendant, a frequent customer who owed the victim money, was linked to the crime through text messages, surveillance footage, and DNA evidence. The victim's cell phones and a pill bottle with her name were missing, and a bloodstained jacket containing these items was found near the defendant's residence.The case was initially tried in the Superior Court, where the defendant was found guilty. The defendant appealed, arguing that the trial judge erred in admitting Y-STR DNA evidence, a compilation exhibit, and testimony from a substitute DNA analyst. He also contended that there was insufficient evidence to support the armed robbery charge.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the Y-STR DNA evidence was properly admitted, as it was presented with sufficient context for the jury to evaluate its significance. The court also found that the substitute analyst's testimony was not hearsay and that the compilation exhibit did not prejudice the defendant. Finally, the court concluded that there was sufficient evidence to support the armed robbery charge, as the jury could reasonably infer that the defendant took the victim's cell phones and pill bottle with the intent to steal.The Supreme Judicial Court affirmed the defendant's conviction and declined to grant relief under G. L. c. 278, § 33E, finding no reason to reduce the conviction or order a new trial. View "Commonwealth v. Souza" on Justia Law

The defendant was convicted of uttering after cashing a forged check drawn on an account of a person who did not know her. On January 19, 2019, the defendant cashed a personal check for $3,600 at a bank, presenting her driver's license. The check was drawn from an account belonging to an individual named Eileen, whose first name was misspelled on the check. The account holder later discovered unauthorized checks drawn on her account and contacted the police. The defendant was charged with larceny by check and uttering.The case was initially tried in the Malden Division of the District Court Department, where the defendant was found guilty of uttering but not guilty of larceny. The defendant's motion for a required finding of not guilty was denied. The Appeals Court affirmed the conviction, and the Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed the evidence to determine if it was sufficient to prove beyond a reasonable doubt that the defendant knew the check was forged. The court found that the evidence, including the account holder's unfamiliarity with the defendant, the misspelled signature, and the amount of the check, was insufficient to establish the defendant's knowledge of the forgery. The court emphasized that the evidence must be more than conjecture or inference piled upon inference. Consequently, the court reversed the judgment of the District Court, set aside the verdict, and ordered that judgment be entered for the defendant. View "Commonwealth v. Oliver" on Justia Law

The defendant was convicted of two counts of assault and battery by means of a dangerous weapon after attacking two victims with a hammer. The defendant admitted to hitting the victims but claimed self-defense. During the trial, the prosecution introduced a text message and social media posts to demonstrate the defendant's animosity toward the victims. The defendant sought to call an expert to dispute the authenticity of these posts, but the trial judge excluded the expert's testimony due to untimely disclosure.The case was first tried in the Superior Court, where the defendant was found guilty of more severe charges. On appeal, the Supreme Judicial Court reversed the convictions and ordered a new trial due to the improper exclusion of expert testimony. In the retrial, the defendant was convicted of the lesser included offense of assault and battery by means of a dangerous weapon. The Appeals Court later reversed these convictions, finding errors in the admission of the social media posts and the exclusion of the expert testimony. The Supreme Judicial Court then granted further appellate review.The Supreme Judicial Court of Massachusetts affirmed the trial court's decisions. The court held that the text message and social media posts were admissible as they were probative of the defendant's animus and intent, and their probative value was not outweighed by the risk of unfair prejudice. The court also found no abuse of discretion in excluding the expert testimony, as the late disclosure prejudiced the Commonwealth and the testimony was minimally material to the case's outcome. The judgments were affirmed. View "Commonwealth v. Hinds" on Justia Law

F.A. has been involuntarily committed to state mental health facilities since 1999 after being found not guilty of a sexual offense due to mental illness. In 2020, a District Court judge renewed F.A.'s commitment and imposed a restriction confining F.A. to the buildings and grounds of the facility. F.A. challenged the constitutionality of this restriction.Previously, the Worcester Division of the District Court Department had renewed F.A.'s commitment annually and imposed similar restrictions since 2013. In 2020, F.A. opposed the Commonwealth's motion for the restriction, but the judge granted it after an evidentiary hearing. The judge did not require the Commonwealth to prove beyond a reasonable doubt that the restriction was necessary. In 2021, a different judge imposed the same restriction without an evidentiary hearing. The Appellate Division of the District Court affirmed the 2020 restriction but vacated the 2021 restriction due to the lack of a hearing. F.A. appealed the 2020 decision, and the Supreme Judicial Court granted direct appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the 2020 order violated F.A.'s substantive and procedural due process rights. The court held that a restriction under G. L. c. 123, § 16 (e) must be narrowly tailored to a compelling government interest and be the least restrictive means available. The judge failed to make such findings and did not consider less restrictive alternatives. Additionally, the court found that the judge used an incorrect standard of proof and did not provide timely, specific findings to support the restriction. Consequently, the court vacated the 2020 order. View "In the Matter of F.A." on Justia Law

In two separate cases, mothers petitioned the Juvenile Court to involuntarily commit their children for inpatient care due to substance use disorders under Massachusetts General Laws c. 123, § 35. E.S. was committed for ninety days, and J.P. for thirty days, following hearings where family members and court clinicians testified about the juveniles' substance use and behaviors.In the case of E.S., the Bristol County Juvenile Court judge found clear and convincing evidence of a substance use disorder, citing E.S.'s history of alcohol and marijuana use, recent positive tests for fentanyl, and concerning behaviors such as stumbling and passing out. The judge also found a likelihood of serious harm due to the imminent risk posed by E.S.'s substance use and the lack of immediate outpatient care options. E.S.'s commitment was affirmed on appeal.For J.P., the Essex County Juvenile Court judge ordered commitment based on testimony about J.P.'s daily marijuana use, behavioral changes, and a single incident of driving under the influence. However, the court clinician did not find J.P. to be a danger to himself or others. On appeal, the Supreme Judicial Court found the evidence insufficient to support a likelihood of serious harm, noting the lack of clear evidence of imminent risk. J.P.'s commitment order was reversed.The Supreme Judicial Court of Massachusetts held that a finding of a substance use disorder under § 35 must be supported by clinical evidence to comply with substantive due process. The court affirmed E.S.'s commitment but reversed and vacated J.P.'s commitment, remanding the case for entry of an order consistent with its opinion. View "In the Matter of J.P." on Justia Law