Justia Massachusetts Supreme Court Opinion Summaries

In 1999, the defendant admitted to sufficient facts to support a finding of guilty for distributing a class A substance. He later sought to withdraw this admission, claiming his plea counsel failed to inform him that it would lead to mandatory deportation. The defendant, a legal permanent resident since 1994, argued that he would have insisted on going to trial had he known the immigration consequences, citing his strong ties to the United States, including his American citizen wife and children, and his consistent employment as a welder.The defendant's initial motion for a new trial was denied due to the absence of an affidavit from his plea counsel. He then filed a renewed motion with the necessary affidavit, which was also denied by a District Court judge after a non-evidentiary hearing. The judge concluded that while the plea counsel was ineffective, the defendant failed to demonstrate prejudice. The Appeals Court affirmed this decision.The Supreme Judicial Court of Massachusetts reviewed the case, focusing on whether the defendant established prejudice from his counsel's ineffectiveness. The court found that the motion judge improperly assessed the defendant's claim by not applying the reasonable person standard and by making credibility determinations about the defendant's assertion that he would have gone to trial. The court vacated the denial of the renewed motion and remanded the case for further findings on whether the defendant's ties to the United States constituted special circumstances and whether a reasonable person in his situation would have chosen to go to trial if properly advised. View "Commonwealth v. Torres" on Justia Law

An undercover police officer, without a warrant, used his cell phone to make audio-visual recordings while purchasing drugs from the defendant. These recordings captured both the audio of their conversations and video footage of the defendant. The defendant was subsequently charged with multiple counts of drug distribution and moved to suppress the recordings, arguing they were unlawful interceptions under the wiretap act.The Superior Court judge partially granted the motion, suppressing the audio but allowing the video footage to be used as evidence if shown silently. Both parties sought interlocutory appeal. The Appeals Court ruled that both the audio and video components must be suppressed under the wiretap act. The Commonwealth then sought further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and held that the wiretap act's suppression remedy extends to both the audio and video components of the recordings. The court reasoned that the video footage, even without audio, contains information about the identity of the parties and the existence of the communication, which falls under the statute's definition of "contents." Therefore, the entire recording must be suppressed to align with the legislative intent of protecting privacy and deterring unauthorized surveillance.The court affirmed the suppression of the audio and reversed the decision allowing the video footage, ordering that both components be suppressed. View "Commonwealth v. Du" on Justia Law

On August 14, 2018, Yashua Amado, Darrell Smith, and Jerome Smith were shot while sitting in Amado's car on Deering Road in Mattapan. Amado was killed, and Darrell and Jerome sustained non-life-threatening injuries. The shooter was never identified. Dewane M. Tse was indicted for first-degree murder and two counts of armed assault with intent to murder, accused of participating in a joint venture by following the victims and driving the shooter to and from the crime scene.In the Superior Court, a jury convicted Tse of first-degree murder based on deliberate premeditation regarding Amado and armed assault with intent to murder Darrell. Tse was acquitted of the charge related to Jerome. Tse's motions for required findings of not guilty were denied by the trial judge, who sentenced him to life without parole for the murder and a concurrent term for the assault. Tse appealed, arguing insufficient evidence to prove he knowingly participated in the shooting or shared the shooter's lethal intent.The Supreme Judicial Court of Massachusetts reviewed the case. The court found insufficient evidence to prove beyond a reasonable doubt that Tse knew of or shared the shooter's lethal intent. The court noted that the evidence, including GPS data, cell site location information, and video footage, did not establish Tse's knowledge or intent to kill. The court emphasized that the Commonwealth's argument relied on speculative assertions about Tse's maneuvering of the vehicle, which was insufficient to prove shared lethal intent.The court reversed Tse's convictions for first-degree murder and armed assault with intent to murder, set aside the verdicts, and remanded the case to the Superior Court for entry of required findings of not guilty. View "Commonwealth v. Tse" on Justia Law

A juvenile was seen masturbating in a parked car and was charged with open and gross lewdness and lascivious behavior, a felony. At trial, the jury was also instructed on the lesser included offense of indecent exposure, a misdemeanor punishable by no more than six months in jail. The jury found the juvenile delinquent only of the lesser included offense. The juvenile, who had no prior offenses, argued that the delinquency adjudication must be dismissed for lack of subject matter jurisdiction.The Juvenile Court judge denied the motion to dismiss and sentenced the juvenile to a continuance without a finding until his nineteenth birthday, after which the charge was dismissed. The juvenile appealed, and the Supreme Judicial Court transferred the case from the Appeals Court to address whether the Juvenile Court retained jurisdiction over a first offense of a minor misdemeanor after a jury trial.The Supreme Judicial Court concluded that once the jury found the juvenile delinquent only of a minor misdemeanor and it was undisputed that it was his first offense, the Juvenile Court no longer had subject matter jurisdiction. The court held that the delinquency adjudication should have been dismissed and recorded only as a Wallace W. determination. The court vacated the adjudication of delinquency and remanded the matter to the Juvenile Court with instructions to make the appropriate entry. View "Commonwealth v. Vince V." on Justia Law

The case involves a dispute over the interpretation of a statutory provision requiring the Executive Office of Housing and Livable Communities (HLC) to provide immediate temporary emergency shelter to families who appear to be eligible based on their statements and information already in the agency's possession. The plaintiffs, representing a class of individuals, argued that HLC's requirement for third-party verification of identity, familial relationship, and Massachusetts residency at the time of initial application for emergency assistance shelter was contrary to the statutory language.The Superior Court judge ruled that HLC could not require third-party verification of Massachusetts residency but could require verification of family status and identity, except for pregnant women. Both parties appealed this decision.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the plain language of the statutory provision did not permit HLC to require third-party verification at the time of initial application. The court emphasized that the statute mandates immediate provision of shelter based on the family's statements and information in HLC's possession, without delay. The court found that the requirement for third-party verification at the initial application stage would contradict the statute's intent to provide immediate temporary shelter to those in need.The Supreme Judicial Court reversed the Superior Court's judgment to the extent it allowed HLC to require third-party verifications before providing shelter under the immediate placement proviso. The judgment was otherwise affirmed. View "Garcia v. Executive Office of Housing and Livable Communities" on Justia Law

On August 14, 2018, Yashua Amado, Darrell Smith, and Jerome Smith were shot while sitting in Amado's car on Deering Road in Mattapan. Amado was killed, and Darrell and Jerome sustained non-life-threatening injuries. The shooter was never identified. Dewane M. Tse was indicted for first-degree murder and two counts of armed assault with intent to murder, accused of participating in a joint venture by following the victims and driving the shooter to and from the crime scene.In the Superior Court, a jury convicted Tse of first-degree murder based on deliberate premeditation regarding Amado and armed assault with intent to murder Darrell. Tse was acquitted of the charge related to Jerome. Tse's motions for required findings of not guilty were denied by the trial judge, who sentenced him to life without parole for the murder and a concurrent term for the armed assault. Tse appealed, arguing insufficient evidence to prove he knowingly participated in the shooting or shared the shooter's lethal intent.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the evidence was insufficient to prove beyond a reasonable doubt that Tse knew of or shared the shooter's lethal intent. The court noted that the Commonwealth's reliance on the manner in which Tse maneuvered the vehicle was speculative and did not establish the necessary intent. Consequently, the court reversed Tse's convictions for first-degree murder and armed assault with intent to murder, set aside the verdicts, and remanded the case to the Superior Court for entry of required findings of not guilty. View "Commonwealth v. Tse" on Justia Law

A clerk-magistrate decided to allow public access to show cause hearings for individuals accused of being clients of a prostitution ring but denied media requests for the underlying complaint applications before the hearings. The accused individuals, referred to as John Does, intervened to oppose the public access decision and sought to keep the hearings private. The media outlets filed a petition in the Supreme Judicial Court for Suffolk County to challenge the clerk-magistrate's decision to withhold the complaint applications.The single justice of the Supreme Judicial Court remanded the matter to the clerk-magistrate for written findings on specific questions related to the public interest and privacy concerns. After reviewing the clerk-magistrate's responses, the single justice denied the petition, concluding that the clerk-magistrate did not commit an error of law or abuse her discretion in allowing public access to the hearings and denying access to the complaint applications.The Supreme Judicial Court affirmed the single justice's decision, holding that the clerk-magistrate acted within her discretion. The court found that the public interest in transparency and accountability outweighed the privacy interests of the accused, especially given the significant public attention and the potential for favoritism if the hearings were held privately. The court also agreed that denying access to the complaint applications was appropriate to prevent the dissemination of potentially erroneous or extraneous information before the accused had an opportunity to respond at the hearings.The court further directed the Trial Court to provide notice to the accused when a request for public access to a show cause hearing is made and to offer the accused an opportunity to respond before deciding on the request. View "Trustees of Boston University v. Clerk-Magistrate of the Cambridge Division of the District Court Department" on Justia Law

Bruce Johnson and Caroline Settino were engaged to be married, with Johnson giving Settino a $70,000 diamond engagement ring and two wedding bands. Johnson also paid for various expenses, including part of Settino's dental implant surgery. However, Johnson ended the engagement after discovering messages on Settino's phone that led him to believe she was unfaithful, although the trial judge found no evidence of an affair. Settino kept the engagement ring and wedding bands, and Johnson did not pay for the second part of Settino's dental procedure.Johnson sued to recover the engagement ring and wedding bands, and Settino counterclaimed for the cost of the dental procedure. The Superior Court judge ruled in favor of Settino, allowing her to keep the engagement ring and one wedding band, and awarded her damages for the dental procedure, including prejudgment interest from the date of Johnson's complaint. The judge found Johnson at fault for ending the engagement based on his mistaken belief of infidelity.The Appeals Court reversed the decision, ruling that Johnson was not at fault and should recover the engagement ring and wedding band. The court also found that prejudgment interest should be calculated from the date of Settino's counterclaim, not Johnson's complaint. The Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court of Massachusetts held that the concept of fault should not determine the return of engagement rings. The court adopted a no-fault approach, requiring the return of the engagement ring and wedding bands to the donor if the marriage does not occur, regardless of fault. The court also affirmed the need to recalculate prejudgment interest from the date of Settino's counterclaim. The judgment was reversed in part and remanded for recalculation of prejudgment interest. View "Johnson v. Settino" on Justia Law

The defendant, Carlos Colina, killed Jonathan Camilien in his Cambridge apartment by strangling him in a chokehold and subsequently dismembered the body. The dismembered torso was found in a duffel bag on a nearby walkway, leading investigators to the defendant's apartment where they discovered rap music lyrics describing similar acts. The defendant was convicted of first-degree murder and improper disposal of human remains. He appealed, arguing that the admission of rap lyrics and other evidence was prejudicial and that the search warrants were deficient.The Superior Court denied the defendant's pretrial motion to suppress evidence obtained from search warrants, and the trial judge admitted the rap lyrics and records of the defendant's online purchases. The jury found the defendant guilty, and he was sentenced to life in prison without parole for the murder and six months for improper disposal of human remains.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the convictions. The court held that the rap lyrics were admissible as they were relevant to the defendant's state of mind and intent, and their probative value outweighed any prejudicial effect. The search warrants were found to be supported by probable cause and sufficiently particular. The court also concluded that the trial judge's instructions to the jury were proper and that any errors in the prosecutor's closing argument or the exclusion of certain jury instructions were not prejudicial. The court found no basis for relief under G. L. c. 278, § 33E, and affirmed the judgments. View "Commonwealth v. Colina" on Justia Law

The case involves the interpretation of the Massachusetts Principal and Income Act (MPIA) in relation to trusts established under the will of Helyn W. Kline. Kline's will created separate trusts for her daughters, including Denise Jo Levy, who is the income beneficiary of the trusts at issue here. The will allows the trustees to distribute net income to Levy and, under extraordinary circumstances, to distribute principal in emergencies. Levy's three sons are the remainder beneficiaries. The trustee, Robert Friedman, pursued a total growth investment strategy that increased the trust principal significantly more than the income.In the Probate and Family Court, Peter Judson, one of Levy's sons, filed a petition alleging improper distributions to Levy exceeding the trusts' net income. The trustee justified the distributions by exercising the power to adjust between principal and income under the MPIA, arguing it was necessary to treat all beneficiaries fairly. The Probate and Family Court judge granted summary judgment in favor of the trustee, finding no abuse of discretion in the trustee's actions.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the MPIA permits a trustee to adjust between principal and income if the trust instrument does not clearly deny this power. The court found that Kline's will did not explicitly prohibit the trustee from making such adjustments. The court also concluded that the trustee did not abuse his discretion in exercising the power to adjust, as he considered relevant factors, including the intent of the testator and the needs of the beneficiaries. The court affirmed the Probate and Family Court's decision, allowing the trustee's adjustments and distributions to Levy. View "In the Matter of the Trusts under the Will of Kline" on Justia Law