Justia Massachusetts Supreme Court Opinion Summaries
Schajnovitz v. Commonwealth
The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner was charged with assault and battery on a family or household member, malicious destruction of property, and intimidation of a witness. After Petitioner unsuccessfully filed several motions to dismiss he filed his Mass. Gen. Laws ch. 211, 3 arguing that the complaint had not been signed by the correct police officer and proceeding to trial on the basis of a nonconforming criminal complaint would violate his due process rights. The previously unsigned complaint was subsequently signed and sworn in open court. Thereafter, the single justice denied Petitioner's Mass. Gen. Laws ch. 211, 3 petition. The Supreme Judicial Court affirmed, holding that there was no reason Petitioner could not obtain his desired relief in a direct appeal. View "Schajnovitz v. Commonwealth" on Justia Law
Kifor v. Commonwealth
The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Petitioner's petition for relief in the nature of certiorari under Mass. Gen. Laws ch. 249, 4, holding that Petitioner failed to establish that he was entitled to extraordinary relief.In his petition, Petitioner sought to have the Supreme Judicial Court intervene in custody and child support proceedings in the probate and family court. The county court denied relief. The Supreme Judicial Court affirmed, holding that the proceedings at issue were reviewable in the ordinary appellate process and that Petitioner, who had twice before sought extraordinary relief in litigation between him and the mothers of his children, was on notice that further attempts to obtain such relief may result in the imposition of sanctions. View "Kifor v. Commonwealth" on Justia Law
Commonwealth v. Ramos
The Supreme Judicial Court reversed the judgment of the superior court denying Defendant's motion filed under Mass. Gen. Laws ch. 278A seeking deoxyribonucleic acid (DNA) testing of fingernail clippings collected from the victim's body to support his argument that the victim was the first aggressor and that Defendant acted in self-defense, holding that the superior court erred.After a jury trial, Defendant was found guilty of murder in the first degree on a theory of deliberate premeditation. While his direct appeal was pending, Defendant brought his chapter 278A motion requesting DNA testing. A motion judge denied the motion, concluding that Defendant failed to meet the requirements of Mass. Gen. Laws ch. 278A, 7(b). The Supreme Judicial Court reversed, holding that Defendant established that a reasonably effective attorney would have requested the DNA testing and analysis. View "Commonwealth v. Ramos" on Justia Law
Commonwealth v. Narvaez
The Supreme Judicial Court affirmed the judgment of the district court dismissing the criminal complaint brought against Defendant for violation of Mass. Gen. Laws ch. 266, 103, holding that urine does not constitute a noxious or filthy substance within the meaning of the statute.While Defendant was being held in a jail cell in order to complete the booking process he urinated on the floor both inside and outside of his cell. Defendant was subsequently charged with vandalizing with a "noxious or filthy substance" in violation of section 103. The district court dismissed the complaint for lack of a probable cause, determining that urine was not a noxious or filthy substance under section 103. The Supreme Judicial Court affirmed, holding (1) urine is not a noxious or filthy substance within the context of section 103; and (2) therefore, the criminal complaint against Defendant lacked probable cause. View "Commonwealth v. Narvaez" on Justia Law
Commonwealth v. Kapaia
The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on the theory of extreme atrocity or cruelty, holding that Defendant's allegations of error were without merit and that there was no reason to reduce the verdict pursuant to Mass. Gen. Laws ch. 278, 33E.On appeal from his conviction, Defendant argued, among other things, that there was insufficient evidence to convict him and that errors in the Commonwealth's opening and closing arguments warranted reversal. The Supreme Judicial Court disagreed and affirmed, holding (1) although portions of the prosecutor's opening statement were improper, the errors did not create a substantial likelihood of a miscarriage of justice; (2) the prosecutor misstated the accuracy of GPS data, but this error did not create a substantial likelihood of a miscarriage of justice; and (3) the prosecutor made a misstatement of evidence during her closing, but the error did not create a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Kapaia" on Justia Law
Carriere v. Department of Correction
The Supreme Judicial Court dismissed Appellant's appeal from a judgment of a single justice of the court denying his petition for extraordinary relief, holding that the appeal was moot.Appellant, who was serving a life sentence after being convicted of murder in the first degree, filed a petition for medical parole. While that petition was pending, Appellant filed his petition for extraordinary relief requesting an order directing the Department of Correction to create a medical parole plan. A single justice denied the petition on the basis that Appellant had an adequate alternative remedy. The Supreme Judicial Court affirmed, holding that because the petition had been denied, this appeal was moot. View "Carriere v. Department of Correction" on Justia Law
Commonwealth v. Ralph R.
The Supreme Judicial Court vacated and set aside Appellant's conviction as a youthful offender and his adjudications of delinquency, holding that the trial judge erred in failing to conduct an inquiry into the jury foreperson's report of "discriminatory comments" being made during deliberations.Appellant, a juvenile, was found guilty for two firearm-related offenses. On appeal, Appellant argued that his right to a trial by a fair and impartial jury was twice violated at his trial. The court of appeals agreed, vacated the judgment and adjudications of delinquency, and set aside the verdicts. The Supreme Judicial Court affirmed, holding (1) the trial judge abused his discretion by not conducting a preliminary inquiry into the foreperson's report that the jury remained capable of impartially rendering a verdict; and (2) because it cannot be determined whether comments reflecting racial, ethnic, or other improper bias were made and, if so, whether they created a substantial risk of a miscarriage of justice, the case must be remanded for further proceedings. View "Commonwealth v. Ralph R." on Justia Law
Doe v. Sex Offender Registry Bd.
The Supreme Judicial Court affirmed the judgment of the Sex Offender Registry Board initiating an upward reclassification of John Doe when he was charged with additional sex offenses, holding that there was clear and convincing evidence supporting the level three classification.In 1998, Doe pleaded guilty to the sexual assault of victim one and was classified as a level two sex offender. In 2009, Doe was found guilty of two counts of rape and abuse of a child without force and three counts of indecent assault and battery on a person age fourteen or older involving victim two. In 2010, Defendant was found guilty of two counts of rape of a child as to victim three. After Defendant was charged with the additional sex offenses relating to victims two and three, the Board notified Doe of his duty to register as a level three sex offender. The superior court and appeals court upheld the Board's decision. The Supreme Judicial Court affirmed, holding that the hearing examiner's decision was supported by substantial evidence and was not arbitrary or capricious. View "Doe v. Sex Offender Registry Bd." on Justia Law
GreenRoots, Inc. v. Energy Facilities Siting Bd.
The Supreme Judicial Court affirmed the order of the Energy Facilities Siting Board approving a project change petition filed by NSTAR Electric Company, doing business as Eversource Energy, that would move the boundaries of an electric substation 190 feet from the location that had previously been approved, holding that the Board did not err in approving the project change.Specifically, the Supreme Judicial Court held (1) the Board did not err in determining that GreenRoots, Inc. did not satisfy the applicable legal standard for the reopening of a completed adjudicatory proceeding; (2) the Board complied with the statutory and regulatory requirements regarding public participation and environmental justice; and (3) the Board's conclusion that Eversource reasonably addressed risks from future sea level rise under the circumstances was supported by substantial evidence. View "GreenRoots, Inc. v. Energy Facilities Siting Bd." on Justia Law
Waters v. Kearney
The Supreme Court affirmed the judgment of a single justice of the court dismissing as moot Petitioner's petition pursuant to Mass. Gen. Laws. Ch. 211, 3, holding that the single justice did not err or abuse his discretion in dismissing the petition on the basis that it was moot.In 2018, Petitioner commenced this action against Respondent, alleging several tort claims. Shortly before a scheduled pretrial conference in the trial court, Petitioner filed this petition asking the court to, among other things, sanction Respondent. While the petition was pending the underlying case was dismissed for failure to prosecute. The single justice then dismissed Petitioner's Mass. Gen. Laws ch. 211, 3 petition as moot. The Supreme Judicial Court affirmed, holding that the dismissal of the case rendered the issues Petitioner raised on appeal moot. View "Waters v. Kearney" on Justia Law
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