Justia Massachusetts Supreme Court Opinion Summaries

by
The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and assault and battery and several related orders denying postconviction relief, holding that each of Defendant's claims lacked merit. Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's pretrial motion to suppress digital camera images; and (2) the Commonwealth violated its obligation under article 36 of the Vienna Convention on Consular Relations to apprise Defendant of his article 36 rights to representation of counsel of his choice and court-appointed conflict-free counsel, but the error was neither constitutional nor structural. View "Commonwealth v. Fernandes" on Justia Law

Posted in: Criminal Law
by
The Supreme Judicial Court vacated Defendant's conviction for kidnapping but affirmed all other convictions, holding that the verdicts of murder in the first degree were consonant with justice but that Defendant's kidnapping conviction must be vacated because it was based on an inveiglement theory previously dismissed by the motion judge. Defendant was found guilty of three counts of murder in the first degree, kidnapping, and witness intimidation. On appeal, Defendant argued, among other things, that his conviction of kidnapping based on a 2010 incident must be vacated because the theory of kidnapping was invalid or foreclosed by the superior court judge's ruling on a pretrial motion to dismiss. The Supreme Judicial Court agreed, holding (1) Defendant's 2010 kidnapping conviction must be reversed, as the theory on which the prosecution proceeded at trial had previously been dismissed by the court; (2) Defendant was not entitled to relief on his remaining allegations of error; and (3) there is no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or direct the entry of verdicts of a lesser degree of guilt. View "Commonwealth v. Hall" on Justia Law

by
In Father's appeal from a civil contempt order and subsequent judgment on a complaint for unpaid child support filed by Mother, the Supreme Judicial Court held that the judge abused her discretion in holding Father in civil contempt. Mother filed a pro se complaint for civil contempt in the probate and family court alleging that Father, the noncustodial parent, was $3,690 in his child support payments. Father filed an answer and counterclaim for modification, claiming that his past incarceration and subsequent difficulty obtaining employment made past and future payments at the set rate impossible. The judge held Father in contempt and then entered judgment on Father's complaint for modification, reducing his ongoing child support obligation to his requested amount. The Supreme Court vacated the civil contempt judgment against Father, holding (1) Father's case should not have reached the civil contempt hearing stage, (2) the Department of Revenue failed to follow the Federal regulations and its own procedures in failing to assist Father, and (3) the judge failed to provide Father with sufficient procedural safeguards. View "Department of Revenue Child Support Enforcement v. Grullon" on Justia Law

Posted in: Family Law
by
The Supreme Judicial Court held that Defendant's right to choice of private counsel and right to be present during a critical stage of the proceedings under both the federal and state constitutions were violated during his criminal trial, requiring automatic reversal absent waiver, but that the delay of more than thirty years in bringing these claims under these circumstances waived the claims under state and federal constitutional law. In 1982, Defendant was convicted of murder in the first degree. In 2015, Defendant filed a second motion for a new trial asserting that the appointment of his court-appointed, State-funded counsel violated his rights under the Sixth Amendment and article 12 of the Massachusetts Declaration of Rights. The Supreme Judicial Court held (1) Defendant's right to choice of private counsel and right to be present during a critical stage of the proceedings under both the federal and state constitutions were violated, and these violations were structural errors; (2) the delay in bringing these claims combined with the fact that the transcript clearly depicting the constitutional violations was available for Defendant in 1991 and for the public defense counsel screening his claims in 1992-1993 and 2000 waived Defendant's claims; and (3) there was no substantial risk of a miscarriage of justice. View "Commonwealth v. Francis" on Justia Law

by
The Supreme Judicial Court declared that periods of delay resulting from trial continuances pursuant to the Court's emergency orders should be excluded from the computation of time limits on pretrial detention under Mass. Gen. Laws ch. 276, 58A and 58B. In response to the COVID-19 pandemic, the Supreme Judicial Court issued a series of emergency orders designated to protect the public health by minimizing the need for in-person proceedings at court houses. In the orders, the Court continued all criminal jury trials to a date no earlier than September 8, 2020 and declared that the time periods of the trial continuances shall be excluded from speedy trial computations. At issue in these three cases was whether the periods of delay resulting from continuances pursuant to the Court's emergency orders should be excluded from the computation of statutory time limits on pretrial detention under Mass. Gen. Laws ch. 276, 58A or 58B. The Supreme Judicial Court remanded the cases to the single justice for entry of orders directing the lower courts to reconsider their prior orders releasing Defendants from detention under chapter 276, sections 58A and 58B, holding that the time periods of these continuances must be excluded in computing the time limits on pretrial detention. View "Commonwealth v. Lougee" on Justia Law

Posted in: Criminal Law
by
In this personal injury action, the Supreme Judicial Court held that Tenant was not entitled to personal injury damages based on Landlord's failure keep the driveway reasonably free of snow and ice. Tenant was severely injured when he slipped and fell on ice in the driveway adjacent to the premises he rented. A jury found Landlords negligent for failing to exercise reasonable care in keeping the driveway free of ice. However, the jury rendered a verdict of no liability, finding that Tenant was comparatively negligent and more responsible for the injury than Landlords. Based on the jury's finding, the judge found Landlords not liable on Tenant's additional claims alleging breach of the common-law implied warranty of habitability and violation of the statutory covenant of quiet enjoyment. Tenant appealed, arguing that he should recover personal injury damages on his remaining claims because the jury found Landlords negligent. The Supreme Judicial Court affirmed, holding (1) a tenant may not be awarded personal injury damagers on a claim for breach of the implied warranty of habitability arising from a landlord's failure to keep common areas reasonably free of snow and ice; and (2) in this case, Tenant may not recover personal injury damages under the statutory covenant of quiet enjoyment. View "Goreham v. Martins" on Justia Law

by
The Supreme Judicial Court affirmed the decision of the Housing Court ordering Defendant to pay $4,000 in use and occupancy to the Bank during the course of his appeal from a judgment in favor of the Bank in a summary process action, holding that the postforeclosure defendant whose appeal bond is waived may be ordered to pay use and occupancy to the plaintiff. After foreclosing on Defendant's property, the Bank obtained judgment in a summary process action against Defendant. Defendant appealed and moved to waive the appeal bond. The judge waived the bond but ordered Defendant to pay monthly use and occupancy to the Bank while the appeal was pending. The Appeals Court vacated the portion of the order requiring use and occupancy payments. The Supreme Judicial Court held (1) the bond for a defendant appealing from an adverse judgment in a postforeclosure summary process action may be waived if he is indigent and pursuing nonfrivolous arguments on appeal; (2) the postforeclosure defendant whose bond is waived may be ordered to pay use and occupancy to the plaintiff; and (3) the amount Defendant was ordered to pay as use and occupancy in this case reflected a fair balancing of interests. View "Bank of New York Mellon v. King" on Justia Law

by
The Supreme Court affirmed the judgment of a single justice denying the Commonwealth's petition, filed pursuant to Mass. Gen. Laws ch. 211, 3, for relief from an interlocutory order the superior court in an underlying criminal case without deciding the merits, holding that the single justice did not abuse her discretion in denying the petition. Defendant was indicted on numerous firearm and ammunition charges. Defendant filed in the trial court a motion for discovery pursuant to Mass. R. Crim. P. 17(a)(2) seeking Boston police department records concerning social media surveillance on Snapchat. In his motion, Defendant asserted that the Boston police department was using Snapchat as an investigatory tool almost exclusively against black males and sought discovery he claimed would support a claim of racial discrimination. The superior court judge allowed the motion. The Commonwealth filed its Mass. Gen. Laws ch. 211, 3 petition, arguing that the judge erred in concluding that Defendant had met his burden in asserting selective prosecution that would warrant the requested discovery. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that the matter did not warrant the exercise of the Court's extraordinary general superintendence power. View "Commonwealth v. Dilworth" on Justia Law

Posted in: Criminal Law
by
The Supreme Judicial Court affirmed the judgment of the single justice denying, without a hearing, Defendant's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion by denying relief. After Defendant's motion to suppress was allowed, the Commonwealth applied for leave to prosecute an interlocutory appeal. A single justice allowed the application and directed the appeal to the Appeals Court. An interlocutory appeal was entered more than a year after the single justice granted the Commonwealth leave to appeal. Defendant filed a motion to dismiss the underlying charges, arguing that his speedy trial and due process rights had been violated. The motion was denied. Defendant then filed his Mass. Gen. Laws ch. 211, 3 petition seeking leave to cross-appeal from the denial of his motion to dismiss. The single justice denied relief. The Supreme Court affirmed, holding that Defendant did not show that the ordinary process of trial and appeal was inadequate for him to obtain review of his speedy trial and due process claims. View "Ramos v. Commonwealth" on Justia Law

by
The Supreme Judicial Court held that the sentencing judge imposed illegal sentences by entering continuances without a finding and immediately dismissing criminal charges without imposing any terms and conditions or probation, but the Court declined to remand the case for resentencing as to the legal sentences because ordering Defendant to be resentenced would not be just. Defendant was charged with several offenses in connection with three separate instances. The judge sentenced Defendant to thirty days in a house of correction for the charge of assault and battery and entered continuances without a finding and dismissed all remaining charges. The Commonwealth appealed, arguing that the continuances without a finding, which were immediately dismissed without any terms and conditions, constituted illegal sentences under Mass. Gen. Laws ch. 278, 18. The Supreme Judicial Court held (1) the continuances without a finding constituted illegal sentences because they contained no terms and conditions; but (2) it would be unfair to Defendant to vacate a disposition reflecting what appeared to be a common practice, and so this ruling applies prospectively from the date of this decision. View "Commonwealth v. Ellsworth" on Justia Law

Posted in: Criminal Law