Justia Massachusetts Supreme Court Opinion Summaries

The defendant was indicted for carrying a firearm without a license and as an armed career criminal under Massachusetts law, based on three prior convictions for violent crimes. These convictions arose from three separate prosecutions, but all of the offenses were committed before the defendant was convicted or sentenced for any of them. The Commonwealth sought an enhanced sentence under the armed career criminal statute, relying on these prior convictions as predicate offenses.Initially, a judge in the Superior Court denied the defendant’s motion to dismiss the portion of the indictment that alleged more than one qualifying predicate conviction, accepting the Commonwealth’s argument that the “sequential prosecution rule” from Commonwealth v. Resende was not binding precedent but rather obiter dictum. Upon reconsideration, the same judge reversed course, finding that the relevant language in Resende was binding and applied to the facts of this case, and therefore granted the defendant’s motion to dismiss the enhanced sentencing portion of the indictment. The Commonwealth then sought and was granted direct appellate review by the Supreme Judicial Court.The Supreme Judicial Court of Massachusetts reviewed whether the interpretation of “arising from separate incidences” in Resende, which requires “separate, sequential prosecutions” for prior convictions to serve as predicate offenses under the armed career criminal statute, was binding precedent. The court held that Resende’s interpretation was not obiter dictum but was necessary to its reasoning and thus binding. Applying this rule, the Supreme Judicial Court affirmed the lower court’s dismissal of the armed career criminal enhancement, concluding that the defendant’s prior convictions did not satisfy the sequential prosecution requirement. View "Commonwealth v. Lewis" on Justia Law

During a daytime traffic stop in Lawrence, Massachusetts, a police officer encountered a sixteen-year-old juvenile who had been reported missing by the Department of Children and Families. The juvenile was seated in a vehicle with an infant and three adults, one of whom was known by the officer to be affiliated with a street gang. The officer ordered the juvenile out of the car without asking any questions and immediately conducted a patfrisk, discovering a handgun on the juvenile’s person. The juvenile was subsequently charged with multiple firearms offenses and indicted as a youthful offender on one count.The Essex County Juvenile Court reviewed the juvenile’s motion to suppress evidence obtained from the exit order and patfrisk, arguing violation of constitutional rights. After an evidentiary hearing, the judge granted the motion to suppress, finding the officer's actions unjustified under the circumstances. The Commonwealth sought interlocutory review, and a single justice of the Supreme Judicial Court for the county of Suffolk allowed the appeal. The Appeals Court reversed the suppression order, concluding the officer’s actions were reasonable under the community caretaking doctrine. The Supreme Judicial Court then granted further appellate review.The Supreme Judicial Court of Massachusetts held that the officer’s exit order was justified under the community caretaking doctrine, as the officer was acting to ensure the safety and well-being of a missing juvenile. However, due to inconsistencies in the Juvenile Court judge’s findings regarding the credibility of the officer’s testimony about key facts supporting the patfrisk, the Supreme Judicial Court vacated the suppression order. The case was remanded to the Juvenile Court for clarification of factual findings and reconsideration of the legal conclusions in light of those findings and the Supreme Judicial Court's opinion. View "Commonwealth v. Demos D." on Justia Law

The defendant, between the ages of forty-seven and forty-nine, was accused of sexually abusing a child who was eight to ten years old during the relevant period from 2013 to 2015. Based on these allegations, a grand jury indicted the defendant on six counts under a specific subsection of the aggravated child rape statute, which applies when the victim is twelve to sixteen years old and there is more than a ten-year age difference between the defendant and the victim. However, the alleged victim was under twelve years old at the time of the offenses.Recognizing this discrepancy, the Commonwealth moved to amend the indictments to charge the defendant under a different subsection of the statute, which applies when the victim is under twelve and there is more than a five-year age difference. The Superior Court granted this motion over the defendant’s objection, and the defendant was subsequently convicted by a jury on five counts under the amended subsection. The defendant’s motion for a required finding of not guilty, arguing the amendments were improper, was denied. The Appeals Court later affirmed the convictions.On further appellate review, the Supreme Judicial Court of Massachusetts considered whether it was permissible to amend the indictments to change the statutory subsection under which the defendant was charged. The court held that such amendments were substantive, not merely of form, because they changed an essential element—specifically, the age of the victim required for conviction under each subsection. The court found that this type of amendment violated the defendant’s constitutional right to be indicted for the specific crime charged, as guaranteed by Article 12 of the Massachusetts Declaration of Rights. As a result, the Supreme Judicial Court reversed the convictions for aggravated child rape, set aside the verdicts, and remanded the case for entry of judgments of not guilty on those indictments and for resentencing. View "Commonwealth v. McCaffrey" on Justia Law

The defendant killed his former high school girlfriend by strangling and cutting her throat after their relationship ended. In the months leading up to the crime, he exhibited signs of emotional distress and had several altercations with the victim and others. On the day of the killing, he took calculated steps to conceal his involvement, including moving the victim’s body, cleaning evidence, and misleading police about their interactions. During trial, the defendant admitted to the killing but argued he was not criminally responsible due to mental illness, presenting expert testimony regarding his psychological state.In the Superior Court, the defendant was convicted of first-degree murder on theories of deliberate premeditation and extreme atrocity or cruelty, along with assault and battery charges. He was sentenced to life without parole. After his conviction, he filed a motion to suppress evidence obtained from searches of his home and vehicle, arguing lack of probable cause, which the court denied. Later, he moved for a new trial, citing newly discovered evidence of developing schizophrenia after the crime. After an evidentiary hearing, a Superior Court judge denied the motion, finding the new evidence did not cast real doubt on the justice of the conviction.The Supreme Judicial Court of Massachusetts reviewed the consolidated appeals from the convictions and denial of the new trial motion. The court held that the lower court did not err or abuse its discretion in denying the new trial or in its evidentiary rulings. It also found the denial of the suppression motion proper, concluding the warrants were supported by probable cause. The court affirmed all convictions and the denial of the new trial motion. However, it held that the sentence of life without parole was unconstitutional for defendants under twenty-one and remanded for resentencing to life with parole eligibility after fifteen years. View "Commonwealth v. Fujita" on Justia Law

After experiencing medical complications following a delayed appendectomy, a nineteen-year-old patient brought a medical malpractice action against a hospital, its corporate affiliate, and several health care providers. The patient had gone to the hospital's emergency department with abdominal pain and other symptoms and was initially diagnosed with a urinary tract infection and discharged. She returned the next day with worsening pain, was diagnosed with acute appendicitis, and underwent surgery after a twelve-hour delay. The appendicitis had perforated, resulting in additional surgeries and complications, including abdominal abscess and pleural effusion, and a prolonged hospital stay.The patient filed her complaint in the Superior Court, alleging negligence and adverse consequences from delayed diagnosis and treatment. She moved to impound her medical records, arguing for their confidentiality, but the judge denied her motion, citing failure to show good cause and allowing her to refile with more specificity, which she declined. She also sought a protective order, which was similarly denied. For the medical malpractice tribunal process, the plaintiff submitted an expert opinion letter without her medical records. The tribunal found the offer of proof insufficient to raise a legitimate question of liability for judicial inquiry. The plaintiff failed to post the required bond within thirty days of the tribunal’s finding, resulting in dismissal of her claims. The Appeals Court affirmed both the dismissal and the denial of impoundment.On further appellate review, the Supreme Judicial Court of Massachusetts held that the judge did not abuse discretion in denying impoundment of the medical records, as the plaintiff failed to provide particularized information or establish good cause. The court also held that the medical malpractice tribunal did not err in finding the offer of proof insufficient, as it lacked specific information regarding each defendant’s conduct. The Supreme Judicial Court affirmed both the denial of the impoundment motion and the judgment of dismissal. View "DosSantos v. Beth Israel Deaconess Hospital-Milton, Inc." on Justia Law

On the evening of July 4, 2018, a man was killed while sitting with his wife on a Boston sidewalk watching fireworks. The defendant drove his girlfriend’s car with Travis Phillips in the passenger seat. As they passed the victim, Phillips used a laser-guided firearm to shoot and kill him. Security footage captured both the events leading up to and following the shooting. Evidence linked the defendant to the car, including fingerprint and DNA analysis, and to the distinctive clothing he wore that night. Police also discovered and seized a cell phone from the defendant’s bedroom, which contained photographs and metadata relevant to the timeline and location of the shooting.The defendant was indicted on charges of murder in the first degree and unlawful possession of a firearm in the Massachusetts Superior Court. He filed two motions to suppress evidence related to the cell phone, both of which were denied. His theory at trial was that the Commonwealth had failed to prove he was the driver or that he shared Phillips's lethal intent. A jury convicted him on both charges. He appealed directly to the Supreme Judicial Court of Massachusetts, raising arguments about sufficiency of evidence regarding intent, prosecutorial misconduct in statements and arguments, and the legality of the cell phone search and seizure.The Supreme Judicial Court of Massachusetts affirmed the murder conviction, holding that the evidence was sufficient to permit the jury to find shared lethal intent, that the prosecutor’s statements did not exceed permissible bounds, and that the seizure and search of the cell phone were supported by probable cause and not unreasonably delayed or overly broad. However, the court vacated the firearm conviction and remanded for further proceedings because the jury had not been instructed that the Commonwealth bore the burden of proving the absence of a valid firearms license. View "Commonwealth v. Carleton" on Justia Law

The defendant and his girlfriend entered the home of an elderly couple, Thomas Harty and Joanna Fisher, where they stabbed and suffocated the victims, stole their valuables, and fled in the victims’ car. Harty died immediately. Fisher, a nonambulatory, seventy-seven-year-old woman who used a wheelchair, survived initially but later died from complications due to multiple stab wounds. The defendant was convicted of murder in the first degree for both victims and, as to Fisher, also of attempted murder.Previously, the Supreme Judicial Court of Massachusetts reviewed and affirmed the convictions, but noted that the jury instruction for attempted murder incorrectly included the failure to complete murder as an element. The court allowed the defendant to raise the issue of legally inconsistent verdicts in a postconviction motion. The Superior Court, after considering whether the acts supporting the attempted murder and murder convictions were sufficiently separate and whether the defendant had notice of alternate theories, found both questions answered in the affirmative and denied the defendant’s motion to vacate the convictions.On further appeal, the Supreme Judicial Court of Massachusetts held that the verdicts were not legally inconsistent. The court concluded that the jury could reasonably have found that the defendant’s act of attempting to smother Fisher with pillows was separate from the subsequent fatal stabbing, and each act could support distinct convictions. The court also found that the defendant received adequate notice of the theories underlying each charge. Therefore, the court affirmed the order denying the defendant’s motion to vacate the convictions, holding that no substantial likelihood of a miscarriage of justice resulted from the erroneous jury instruction. View "Commonwealth v. Hart" on Justia Law

Kelsey Fitzsimmons, a North Andover police officer, was indicted in Essex County on one count of assault by means of a dangerous weapon. The Commonwealth alleged that during the service of an abuse prevention order, Fitzsimmons deceived officers regarding firearms in her home, drew a firearm, pointed it at an officer, and pulled the trigger, though the gun did not discharge. She then allegedly attempted to chamber a round before being shot by an officer. The Commonwealth presented further evidence of Fitzsimmons’s prior alcohol-related violence, mental health struggles, and a 2019 misdemeanor conviction for intoxicated and disruptive behavior. Fitzsimmons relied on medical and psychological evidence suggesting she was suitable for outpatient care and posed no credible risk of harm.Initially, the District Court ordered Fitzsimmons held on dangerousness grounds. A Superior Court judge subsequently found her dangerous but released her subject to strict conditions, including house arrest, GPS monitoring, and alcohol abstinence monitored by SCRAM testing. When Fitzsimmons claimed she could not physically comply with SCRAM testing due to injuries, the judge vacated the release order and detained her pretrial. Fitzsimmons moved for reconsideration, proposing urine testing as an alternative, but the judge denied the motion, finding that urine testing would interfere with house arrest requirements.Fitzsimmons then petitioned a single justice of the Supreme Judicial Court of Massachusetts for extraordinary relief under G. L. c. 211, § 3, arguing the judge erred in refusing less restrictive alternatives and in her conduct. The single justice denied the petition, concluding there was no error or abuse of discretion. On appeal, the Supreme Judicial Court affirmed, holding that neither the hearing judge nor the single justice abused their discretion in ordering detention when Fitzsimmons could not comply with the least restrictive conditions necessary for community safety. The Court also found no requirement for de novo review and rejected Fitzsimmons’s arguments under the Americans with Disabilities Act and other statutes. Judgment was affirmed. View "Fitzsimmons v. Commonwealth" on Justia Law

The case concerns a defendant who pleaded guilty in 2012 to multiple sex offenses involving his minor children. He was sentenced to ten years in state prison followed by ten years of probation, with mandatory global positioning system (GPS) monitoring as a condition of probation under Massachusetts law. The statute required GPS monitoring for the entirety of his probation, but at the time of sentencing, no specific exclusion zones were established. After serving his prison sentence and two years of probation with GPS monitoring, the defendant sought relief from the GPS monitoring condition, arguing that it was unreasonable and unconstitutional, particularly due to its ten-year duration.After the Supreme Judicial Court’s decision in Commonwealth v. Feliz, which required individualized judicial findings regarding the reasonableness of GPS monitoring as a probation condition, the defendant filed a motion in the Superior Court for such an individualized assessment. The Superior Court judge denied the motion, finding that the Commonwealth had shown continued GPS monitoring was reasonable, based in part on the defendant’s classification as a level three sex offender and the victims’ statements about ongoing harm. However, the judge did not make findings regarding the reasonableness of the specific ten-year duration of GPS monitoring.The Supreme Judicial Court of Massachusetts reviewed the case on direct appellate review. The Court held that a judge must consider the duration of GPS monitoring in evaluating its reasonableness under the Massachusetts Declaration of Rights. The holding clarified that a judge may only impose GPS monitoring for a duration found to be reasonable, even if that period is less than the statutory term of probation. Because the Superior Court judge did not evaluate the ten-year duration, the Supreme Judicial Court vacated the order denying the defendant’s motion and remanded for further proceedings consistent with its opinion. View "Commonwealth v. Arnold" on Justia Law

A commercial landlord leased property in downtown Boston to a restaurant operator. As part of their lease agreement, the landlord sold the restaurant a liquor license for one dollar, with the understanding that the license would be transferred back to the landlord for one dollar at the end of the lease. The lease included a provision prohibiting the restaurant from pledging the liquor license as collateral for any loan without the landlord’s written consent. Despite this, before the lease ended, the restaurant pledged the license to its principal as collateral for a loan. When the landlord discovered this, it terminated the lease and demanded the return of the license.The landlord and its related entities filed suit in the Massachusetts Superior Court, alleging breach of contract, unfair or deceptive business practices under General Laws c. 93A, and conversion. The Superior Court granted partial summary judgment for the landlord on the contract claims, finding the anti-pledge provision enforceable and the pledge a default. After a bench trial, the court found for the landlord on the c. 93A and conversion claims, awarding treble damages, attorney's fees, and costs. The defendants appealed these decisions.The Supreme Judicial Court of Massachusetts reviewed the case after transferring it from the Appeals Court. The Supreme Judicial Court held that the anti-pledge provision did not violate public policy or state law and was therefore enforceable. The court affirmed that the principal’s conduct in falsely affirming to regulatory authorities that the pledge did not violate any agreements constituted willful and knowing unfair or deceptive conduct under c. 93A. However, while the court affirmed the breach of contract claim, it reversed the conversion judgment, finding that the landlord did not have actual or immediate right to possession of the license at the relevant time. The award of attorney's fees and costs was affirmed. View "Nicosia v. Burns, LLC" on Justia Law