Justia Massachusetts Supreme Court Opinion Summaries

The plaintiff, Kathleen Vita, alleged that New England Baptist Hospital (NEBH) and Beth Israel Deaconess Medical Center, Inc. (BIDMC) violated the Massachusetts wiretap act by collecting and transmitting her browsing activities on their websites to third parties for advertising purposes without her consent. Vita accessed information about doctors and medical conditions on the hospitals' websites and claimed these interactions were "wire communications" protected by the wiretap act. She did not allege that private patient records or messages to healthcare providers were intercepted.The Superior Court denied the hospitals' motions to dismiss Vita's complaints, leading to the hospitals' appeal. The Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the term "communication" in the wiretap act is ambiguous as applied to web browsing activities. The court found that the legislative history of the wiretap act focused on the secret interception of person-to-person conversations and messaging, particularly private ones, and did not clearly extend to interactions with websites. Given this ambiguity, the court applied the rule of lenity, which requires that any ambiguity in a criminal statute be resolved in favor of the defendant. Consequently, the court concluded that the wiretap act does not unambiguously prohibit the interception of web browsing activities and reversed the Superior Court's denial of the hospitals' motions to dismiss. View "Vita v. New England Baptist Hospital" on Justia Law

On the night of July 1, 2015, the defendant and his accomplice attempted to rob three women working as escorts at different hotels. The first woman denied them entry, the second was robbed at gunpoint, and the third was shot and killed. The defendant and his accomplice were tried jointly, and a jury convicted them of first-degree murder based on felony-murder, among other charges.The Superior Court found the defendant guilty on all charges, including murder in the first degree, attempted armed robbery, unlawful possession of a firearm, armed robbery, home invasion, and armed assault in a dwelling. The defendant appealed, arguing errors in jury selection, improper identification by a police officer, erroneous jury instructions, and the denial of an accident instruction. He also contended that his firearm conviction should be vacated based on a recent court decision.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the trial judge did not abuse discretion in dismissing two jurors for cause due to their lack of comprehension. The court found that the police officer's identification of the defendant in surveillance footage was admitted in error but did not prejudice the defendant due to the overwhelming evidence against him. The court also ruled that the jury instructions were consistent with legal standards and that the defendant was not entitled to an accident instruction due to lack of evidence. The court vacated the defendant's conviction for unlawful possession of a firearm and remanded for a new trial on that charge. The conviction for attempted armed robbery was vacated as duplicative, but the remaining judgments were affirmed. View "Commonwealth v. Jeune" on Justia Law

The case involves Roberto Cruz, who was convicted of two counts of indecent assault and battery on a child under the age of fourteen. The incidents occurred when Cruz, nearly sixty years old, hugged and kissed a thirteen-year-old girl, Jane, without her consent. Cruz was also charged with child enticement and simple assault and battery, but the latter charge was dismissed by the Commonwealth before the trial. The jury acquitted Cruz of child enticement and one count of indecent assault and battery but convicted him of the other two counts.Cruz appealed his convictions, arguing that the evidence was insufficient to prove the assaults were indecent. The Massachusetts Appeals Court agreed, reversing his convictions on the grounds that the conduct did not meet the statutory definition of indecent assault and battery. Following this reversal, Cruz filed a civil lawsuit seeking compensation for wrongful conviction under G. L. c. 258D. The Commonwealth moved for summary judgment, arguing that the reversal did not establish Cruz's innocence of the simple assault and battery charge, which had been dismissed earlier.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the eligibility for compensation under G. L. c. 258D is limited to felony convictions and does not include misdemeanors like simple assault and battery. Therefore, the court affirmed the Superior Court's denial of the Commonwealth's motion for summary judgment and remanded the case for further proceedings. The court concluded that Cruz met the eligibility requirements for compensation as the reversal of his felony convictions tended to establish his innocence of those charges. View "Cruz v. Commonwealth" on Justia Law

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