Justia Massachusetts Supreme Court Opinion Summaries

In this case, the defendant was convicted in 1989 of first-degree murder and larceny. No DNA evidence was presented at trial, as forensic DNA testing was not generally available at the time. Decades later, the defendant, represented by counsel, requested postconviction DNA testing of crime scene evidence, asserting factual innocence and arguing that another person may have been present with the victim after he left the scene. The Commonwealth did not formally oppose the motion, and an agreed-upon order for DNA testing was entered in June 2022. Shortly after, the defendant died before the testing could be completed due to delays in approval for accessing a DNA database and the transmission of some evidence.Following the defendant’s death, the Commonwealth moved in the Superior Court to vacate the testing order, arguing that the defendant’s death rendered the order void, as only living defendants could seek relief under the relevant statute, G. L. c. 278A. The defendant’s counsel opposed, emphasizing that the delay was not the defendant’s fault, that testing could serve public interests and potentially resolve other unsolved crimes, and that costs would not burden the Commonwealth. The judge denied the Commonwealth's motion to vacate.The Supreme Judicial Court of Massachusetts reviewed the case. It held that while only a living person may initiate a motion for postconviction DNA testing under G. L. c. 278A, the statute does not mandate that a validly issued testing order expires upon the movant’s death. The court concluded that the judge retained inherent authority to reconsider or vacate such an order in light of changed circumstances, including death. The court further held that, under the circumstances, the judge did not abuse his discretion in declining to vacate the order, and affirmed the denial of the Commonwealth’s motion. View "Commonwealth v. Tanner" on Justia Law

A pregnant woman working alone at a gasoline station was killed by ligature strangulation during her shift, resulting in her death and that of her viable, unborn child. The defendant, a man known to frequent the area and drive a distinctive black van, was observed at the station around the time of the killings and was later seen with a large amount of cash. He made incriminating statements to police and fellow detainees, and his DNA matched the major profile found on the ligature used in the crime, as well as DNA recovered from the victim’s fingernails.After his conviction in the Superior Court for two counts of first-degree murder and armed robbery, the defendant appealed and filed several motions for a new trial. The Massachusetts Supreme Judicial Court previously affirmed his convictions and denied his first motion for a new trial, vacating only the armed robbery conviction as duplicative. While his direct appeal was pending, the defendant filed a second motion for a new trial in the Superior Court, asserting new grounds: the Commonwealth's failure to disclose an exculpatory segment of an audio recording, alleged anomalies in another police interview recording, and ineffective assistance of counsel for not interviewing or calling potential alibi witnesses.On appeal from the denial of his second motion for a new trial, the Supreme Judicial Court held that the undisclosed audio segment was not prejudicial since its content was substantially similar to evidence already disclosed, and the overwhelming evidence against the defendant precluded a finding of prejudice. The Court also concluded that the alleged recording anomalies were not newly discovered evidence and would not have affected the verdicts. Finally, it found no substantial likelihood of a miscarriage of justice regarding counsel’s performance. The order denying the second motion for a new trial was affirmed. View "Commonwealth v. Bateman" on Justia Law

Late at night, a State Police trooper stopped a car in Taunton for having excessively tinted windows. The driver, who is the defendant, was accompanied by a passenger. During the stop, the officer noticed signs such as the passenger having two cell phones (one believed to be a “burner” phone), matching hand tattoos (suggesting possible gang affiliation), and an odor of unburnt marijuana. After failing several times to confirm the passenger’s identity, the trooper ordered the passenger out, frisked and detained him, then learned of an outstanding warrant for a minor offense. The officer then ordered the defendant out of the vehicle, frisked him, and, within two minutes, asked for consent to search the car. The defendant consented to a search of the front passenger area. The officer found cocaine, fentanyl, a firearm, and ammunition in the car.The Taunton Division of the District Court Department charged the defendant with firearm and drug offenses. The defendant’s pretrial motion to suppress the evidence was denied in part, with the judge finding the initial stop lawful, the consent to search voluntary, and that probable cause justified the search of the locked glove compartment. After a jury trial, the defendant was convicted on several charges. The defendant appealed, and the Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the exit order was unlawful because there was no reasonable suspicion of criminal activity or safety concern, and the search consent was not sufficiently attenuated from the illegal seizure. The evidence obtained should have been suppressed, and its admission was not harmless beyond a reasonable doubt. The Court ordered a judgment of not guilty on the ammunition charge due to insufficient evidence and vacated the remaining convictions, remanding for further proceedings consistent with its opinion. View "Commonwealth v. Robinson" on Justia Law

An individual was convicted in 1997 of indecent assault and battery on a child under fourteen and served a sentence of incarceration. Before his release, the Commonwealth petitioned to have him civilly committed as a sexually dangerous person (SDP) under Massachusetts law. Two qualified examiners evaluated him but, misunderstanding the scope of evidence they could consider, both opined that he did not meet the statutory criteria for an SDP. Despite this, the case proceeded to trial, and, based on other expert testimony and additional evidence, a judge found him to be an SDP and ordered his civil commitment in 2002. The individual unsuccessfully attempted to appeal, and over the years, filed and withdrew several discharge petitions.A Superior Court judge had denied his original motion for summary judgment, finding that a fact finder could rely on other expert testimony, not just that of the qualified examiners. After his commitment, his attempt to appeal the judgment was dismissed as untimely. Years later, he filed a petition for a writ of habeas corpus, arguing that, following the Massachusetts Supreme Judicial Court’s decision in Johnstone, petitioner, 453 Mass. 544 (2009), his commitment was unlawful because neither qualified examiner had opined that he was an SDP. The Superior Court granted the writ, but the Appeals Court reversed, holding that habeas corpus was not available since alternative remedies existed.The Supreme Judicial Court of Massachusetts reviewed the case and held that, under the statutory scheme, the individual was entitled to a required finding of not sexually dangerous where neither qualified examiner so opined. However, the court concluded that habeas corpus was not available because he had alternative remedies, specifically a motion for relief from judgment. The court vacated the grant of habeas corpus and remanded the case to the Superior Court with instructions to treat the petition as a motion for relief from judgment, which must be allowed. View "Pierce, Petitioner" on Justia Law

The defendant, a legal permanent resident who immigrated from the Dominican Republic, was arrested in Massachusetts after police observed him engaging in a suspected drug exchange. Upon searching his vehicle, officers found heroin, cash, and drug paraphernalia, leading to a charge of possession with intent to distribute a controlled substance. In 2018, the defendant pleaded guilty and received a suspended sentence with probation. Approximately two years later, while returning from the Dominican Republic, he was detained by immigration officials who informed him that his conviction made him automatically deportable, a consequence he claims not to have understood when entering his plea.The Salem Division of the District Court Department accepted the guilty plea. In 2022, the defendant moved to withdraw his plea, alleging ineffective assistance of counsel because his attorney had not adequately explained the immigration consequences. He submitted affidavits from himself and his plea counsel, stating that counsel had advised him only of possible citizenship consequences, not the mandatory nature of deportation stemming from the conviction. The motion judge, who was also the plea judge, denied the motion without an evidentiary hearing, finding the affidavits not credible, primarily because they were inconsistent with counsel’s statement during the plea colloquy that immigration consequences had been discussed.The Supreme Judicial Court of Massachusetts reviewed the denial following an unpublished affirmance by the Appeals Court. The Supreme Judicial Court held that the motion judge erred by discrediting the affidavits solely based on perceived inconsistency with the plea colloquy, as the affidavit and colloquy statements were not inherently contradictory. The court vacated the denial of the motion to withdraw the guilty plea and remanded the case for further proceedings, including the possibility of an evidentiary hearing. View "Commonwealth v. Santana" on Justia Law

An employee of a Massachusetts public college, serving as director of facilities and public safety, objected to the college’s failure to report a student’s sexual assault allegations as required under federal law. The employee, who was responsible for campus security and compliance with the federal Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (Clery Act), learned that various college officials had been informed of the student’s allegations over several years, but the incidents were not reported to the U.S. Department of Education as required. The employee raised these concerns with State auditors and the chair of the college’s board of trustees. Subsequently, the college conducted internal and external investigations, which confirmed failures to report the incidents. The employee was later terminated, with the college citing performance deficiencies, including failure to comply with reporting obligations.The employee filed suit in the Massachusetts Superior Court, claiming wrongful termination in violation of the Massachusetts Whistleblower Act (MWA). On cross-motions for summary judgment, the Superior Court judge ruled that the employee engaged in protected activity under the MWA by objecting to the college’s failure to report as required by the Clery Act, but left the question of whether the employee’s whistleblowing or his own purported misconduct caused his termination for the jury. After trial, the jury found in the employee’s favor, awarding damages.The Supreme Judicial Court of Massachusetts reviewed whether the summary judgment ruling on protected activity was correct. The court held that, as a matter of law, an employee objecting to undisputedly unlawful activity—here, the failure to report as required by the Clery Act—engaged in protected activity under the MWA, even if the employee was involved in the underlying wrongdoing. The court affirmed the judgment, concluding the trial judge properly submitted the causation question to the jury. View "Galvin v. Roxbury Community College" on Justia Law

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