Justia Massachusetts Supreme Court Opinion Summaries

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The case revolves around Quasim Hastings, a prisoner convicted of second-degree murder in 2004 and eligible for parole consideration. Hastings, diagnosed with a mental disability, is entitled to a parole hearing that provides him with protections under the Massachusetts Constitution and Federal and State statutes prohibiting discrimination based on disability. Prior to a 2023 parole hearing, Hastings' counsel filed a motion for funds to retain a forensic psychologist and a social services advocate to assist with preparing a prerelease plan. While the motion for a forensic psychologist was approved, the request for a social services advocate was denied by a different Superior Court judge, who reasoned that the indigency statute limits his authority to approve funds to pending proceedings or appeals in any court.The judge's denial of the motion for funds was reported to the Appeals Court, and Hastings's application for direct appellate review was granted by the Supreme Judicial Court. The Supreme Judicial Court concluded that Hastings's motion for funds to retain a social services advocate implicates his State constitutional right to reasonable disability accommodations. Therefore, the constitutionally mandated exception to the indigency statute applies, and the order denying Hastings's motion for funds was reversed. The court held that a judge has the discretion to allow a motion for funds to pay for expert assistance as reasonably necessary to safeguard the indigent prisoner's constitutional rights prohibiting discrimination on the basis of disability. View "Commonwealth v. Hastings" on Justia Law

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The defendant, Warren W. Dunn, was charged with two counts of possession of child pornography and two counts of possession of child pornography as a subsequent offense. The charges were based on evidence found in his apartment during a search conducted under a warrant. The warrant was issued based on an affidavit by a state trooper, who had received a report from the National Center for Missing and Exploited Children (NCMEC) about two images flagged as potential child pornography by Microsoft. The trooper described the images in his affidavit but did not attach them. The defendant had previously been arrested in 2007 for possession of child pornography.In the Superior Court, the defendant filed motions to suppress the evidence and for a hearing on the affidavit supporting the search warrant. The court denied both motions. The defendant then pleaded guilty to all charges, preserving his right to appeal the denials of his motions.The Supreme Judicial Court of Massachusetts affirmed the lower court's decisions. The court held that, although attaching the photographs or providing a more detailed description would have been preferable, the affidavit as a whole was sufficient to establish probable cause for the search warrant. The court also held that the motion judge did not abuse her discretion in concluding that the defendant failed to demonstrate that the trooper's descriptions of the images were false. The court declined to create a new rule requiring magistrates to personally view allegedly lewd images before issuing search warrants. View "Commonwealth v. Dunn" on Justia Law

Posted in: Criminal Law
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The case involves a juvenile who was apprehended with firearms and ammunition and charged with various offenses. After being arraigned as a youthful offender, the juvenile was diagnosed with several information-processing disorders, including a language-based learning disorder. The juvenile was found incompetent to stand trial but capable of attaining competency in the future. However, after two competency proceedings, the juvenile was again found incompetent to stand trial, and the judge declined to make a definite finding on whether the juvenile could attain competency in the foreseeable future. The juvenile filed motions to dismiss the charges under the statute governing the dismissal of pending charges against incompetent persons, but these motions were denied.The Supreme Judicial Court of Massachusetts was tasked with deciding three main issues. First, whether the mental health code provides for the remediation of incompetent juveniles, particularly those incompetent but not mentally ill. Second, whether, in the absence of remediation programming under the mental health code, the ability to create and mandate remediation programming is within the scope of the Juvenile Court's inherent authority. Lastly, whether the pending charges against the juvenile can be dismissed "in the interest of justice."The court held that the mental health code does not provide for the remediation of juveniles found incompetent for reasons other than mental illness. It also rejected the argument that the ability to create and mandate remediation programming for incompetent juveniles falls within the purview of the Juvenile Court's inherent authority, stating that the creation of remediation programming falls within the purview of the Legislature. Regarding the dismissal of charges, the court remanded the matter to the Juvenile Court for further findings on whether the juvenile poses a present danger to the community. View "Makis M. v. Commonwealth" on Justia Law

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The case involves a group of petitioners who challenged a trial court's decision to establish a 200-foot buffer zone around the Norfolk County Superior Court House during the trial of a high-profile murder case. The buffer zone was created in response to protests and demonstrations near the courthouse, which the Commonwealth argued could jeopardize a fair trial. The petitioners, who sought to intervene in the trial court proceedings to oppose the buffer zone, argued that it infringed on their First Amendment rights.The trial judge allowed the Commonwealth's motion for a buffer zone, albeit reducing it from the requested 500 feet to 200 feet. The judge denied the petitioners' motion to intervene, arguing that the buffer zone was necessary to ensure a fair trial and to protect jurors and witnesses from potential intimidation or harassment. The petitioners subsequently filed petitions for relief from both the buffer zone order and the denial of their motion to intervene.The single justice of the Supreme Judicial Court denied the petitions, concluding that the trial judge's decision was an ordinary procedural ruling and did not warrant the court's extraordinary power of general superintendence. The single justice also found that the buffer zone met the "reasonable restriction" requirements, being content-neutral, narrowly tailored to serve a significant governmental interest, and leaving open ample alternative channels for communication.The Supreme Judicial Court affirmed the single justice's decision, rejecting the petitioners' argument that the buffer zone order should be analyzed under strict scrutiny as a prior restraint on speech. The court found that the buffer zone did not forbid protestors from expressing their message, but merely restricted where they could do so. The court also noted that the petitioners failed to provide sufficient evidence to establish that the buffer zone extended onto public sidewalks or other areas constituting a public forum. View "Spicuzza v. Commonwealth" on Justia Law

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The case revolves around a public records request made by Eric Mack, whose brother, Anthony Harden, was fatally shot by police. Mack sought records related to the shooting under Massachusetts public records law. The district attorney's office, which had investigated the shooting, argued that the requested records were exempt from disclosure under three exemptions: the privacy exemption, the policy deliberation exemption, and the investigatory exemption. The Superior Court granted Mack's motion for summary judgment, ordering the disclosure of the requested documents with minor exceptions. The district attorney's office appealed.The Supreme Judicial Court of Massachusetts affirmed in part, reversed in part, and remanded the case. The court held that the privacy exemption did not apply to the requested records because they related to a law enforcement misconduct investigation. The court also held that the policy deliberation exemption did not apply to the draft of the preliminary district attorney's office report, except for the "Applicable Laws" and "Conclusion" sections, which could be redacted. The court remanded the case to the Superior Court to determine whether the investigatory exemption applied to the videotaped public employee interviews and the investigator's interview questions. The court rejected the district attorney's office's argument that the Massachusetts Peace Officer Standards and Training Commission had exclusive authority to release officers' names. View "Mack v. District Attorney for the Bristol District" on Justia Law

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The case involves a professional photographer who sexually exploited a minor. The defendant initially contacted the victim through a social networking site and began communicating with her through various means, eventually soliciting and receiving explicit images of the victim. The defendant also met the victim in person and sexually abused her. After the victim's parents reported the exploitation to the police, an investigation was launched. The police seized a computer tower, an external hard drive, and other items from the defendant's former residence. A forensic examination of the hard drives revealed explicit images of the victim, communications between the defendant and the victim, and hundreds of images of unidentified females in various stages of undress.The defendant was indicted on multiple counts, including aggravated rape of a child and enticement of a minor. He pleaded guilty to all charges, except for the eight counts of aggravated rape of a child, where he pleaded guilty to the lesser included offense of statutory rape. After being sentenced, the defendant filed a motion for the return of the seized property. The Commonwealth opposed the return of the property, arguing that it was in the "public interest" to destroy the devices. The Superior Court denied the defendant's request for the return of certain property.The Supreme Judicial Court of Massachusetts granted an application for direct appellate review. The court concluded that the procedural requirements set forth in G. L. c. 276, §§ 4 to 8, must be followed before a forfeiture decree may be issued under G. L. c. 276, § 3. The court vacated the Superior Court orders denying the return of certain property to the defendant and remanded the case for further proceedings consistent with its opinion. View "Commonwealth v. James" on Justia Law

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The case revolves around Outfront Media LLC (Outfront), a company that entered into a contract with the Massachusetts Bay Transportation Authority (MBTA) to advertise on outdoor signs owned by the MBTA. The city of Boston assessed real estate tax for fiscal year 2021 on Outfront for the signs. Outfront sought an abatement of the tax, arguing that the signs were exempt from taxation under § 24. The city denied Outfront's claim for abatement, and Outfront appealed to the Appellate Tax Board (board), which upheld the tax assessment.The Appellate Tax Board upheld the city of Boston's tax assessment on Outfront Media LLC for the use of outdoor advertising signs owned by the Massachusetts Bay Transportation Authority (MBTA). Outfront had argued that the signs were exempt from taxation under § 24, but the board disagreed, leading to Outfront's appeal.The Supreme Judicial Court of Massachusetts affirmed the decision of the Appellate Tax Board. The court held that Outfront's use of the MBTA's outdoor advertising signs to post advertisements and generate advertising revenue constituted a "use" of the MBTA's property "in connection with a business conducted for profit" under § 24. The court distinguished such businesses from those merely providing a service for the MBTA such as a janitorial service. Therefore, Outfront used the signs within the meaning of § 24 and the decision of the board was upheld. View "Outfront Media LLC v. Board of Assessors of Boston" on Justia Law

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The case involves a nonmarital child who was removed from the mother's custody due to neglect. The Department of Children and Families filed a care and protection petition in the Juvenile Court. The father, who had established paternity but had not sought custody prior to the filing of the petition, was granted temporary custody. The mother later waived her right to a hearing and stipulated that she was unfit, leading to the Juvenile Court judge awarding "permanent" custody to the father. However, the child filed a motion to dismiss the care and protection case, arguing that the Juvenile Court's custody order was sufficient to award permanent custody to the father.The Juvenile Court judge denied the child's motion, citing the statutory scheme which addresses the rights and responsibilities of the parents of nonmarital children. This scheme provides that the mother of a nonmarital child "shall" have custody "[i]n the absence of an order or judgment of a [P]robate and [F]amily [C]ourt [judge] relative to custody." The current practice in the Juvenile Court is to require the parent, who has been awarded permanent custody of the child in connection with a care and protection action, to seek an order of custody from the Probate and Family Court under the nonmarital child statutory scheme.The Supreme Judicial Court of Massachusetts affirmed the Juvenile Court judge's order denying the child's motion to dismiss the care and protection case. The court agreed that the current practice best reflects the Legislature's intent and harmonizes the two statutory schemes. The court also concluded that the practice complies with due process. View "Care and Protection of Jaylen" on Justia Law

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In 2005, Leon Robinson was convicted of first-degree murder and unlawful possession of a firearm for the 2001 shooting death of Recardo Robinson. The incident occurred in a barbershop after an argument between the two men. Several witnesses identified Leon as the shooter. The prosecution also presented evidence of a small bloodstain on Leon's jacket that matched the victim's DNA. Leon appealed his convictions and the denial of his motion for a new trial, arguing that evidence obtained from his apartment was wrongly admitted, his right to self-representation was violated, the prosecutor acted improperly, and his counsel was ineffective.The Superior Court Department had previously denied Leon's pretrial motion to suppress evidence from his apartment. Leon argued that the search warrant was erroneously granted, but the Supreme Judicial Court disagreed, finding that the warrant was supported by probable cause. Leon's motion for a new trial was also denied by the Superior Court Department. He argued that his trial counsel was ineffective for not introducing certain evidence and not retaining expert witnesses, but the Supreme Judicial Court found these decisions to be strategic and not manifestly unreasonable.The Supreme Judicial Court affirmed Leon's murder conviction, finding no errors that would have influenced the jury's decision. However, the court vacated his conviction for unlawful possession of a firearm. The court ruled that, in light of a recent U.S. Supreme Court decision, the absence of a license was an essential element of the firearm possession offense that the prosecution needed to prove. The case was remanded for a new trial on the firearm charge. View "Commonwealth v. Robinson" on Justia Law

Posted in: Criminal Law
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The case revolves around the interpretation of a will and the application of the anti-lapse statute. Heather W. Hossack, the testator, had devised certain assets to her mother, Ethel Wyman, "if she survives me." However, Wyman predeceased Heather. John A. Hossack, Heather's brother, argued that the anti-lapse statute required that the failed devise fall to him. Thomas Gibney, the named beneficiary of the residuary estate, sought a declaration that the phrase "if she survives me" showed Heather's intent to avoid the application of the anti-lapse statute.The case was initially heard in the Essex Division of the Probate and Family Court Department, where the judge allowed summary judgment in favor of Gibney. John appealed the decision, and the Supreme Judicial Court transferred the case from the Appeals Court.The Supreme Judicial Court affirmed the decision of the lower court. The court held that the phrase "if she survives me" demonstrated Heather's intent to avoid the application of the anti-lapse statute. The court reasoned that Heather had contemplated the possibility of Wyman predeceasing her and had expressly provided for it in the will. Therefore, the anti-lapse statute's presumed intention had to yield to the expressed intention of the testator. The court also noted that the will as a whole supported this conclusion, as it specified that a devisee is only considered to have "survived" Heather if the devisee survives her for at least ninety days. View "Gibney v. Hossack" on Justia Law

Posted in: Trusts & Estates