Justia Massachusetts Supreme Court Opinion Summaries

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The Supreme Judicial Court vacated Defendant's guilty plea to a sentencing enhancement and his conviction of unlawful possession of a loaded firearm, holding that where a defendant makes a good faith claim that a deliberating juror reported that racial bias infected the jury's deliberations, a judge may not condition acceptance of a guilty plea to a sentencing enhancement upon a waiver of that claim.Immediately after entry of the guilty verdict in this case, a deliberating juror reported that racial bias influenced the jury's deliberations. Defendant filed a motion to investigate the juror's claims prior to the jury-waived trial on two sentencing enhancements. The prosecutor agreed to nol pros one sentencing enhancement in return for Defendant's guilty plea to the other sentencing enhancement if Defendant withdrew the motion. Defendant withdrew the motion and pleaded guilty to one of the sentencing enhancements. Defendant later moved, unsuccessfully, for a new trial, seeking to vacate his guilty plea to the sentencing enhancement. The Supreme Court ordered a new trial as to the sentencing enhancements, holding that once a defendant's right to a jury trial is invoked a defendant may not waive his right to a verdict that is untainted by racial or ethnic bias. View "Commonwealth v. McCalop" on Justia Law

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The Supreme Judicial Court affirmed the decision of the land court judge dismissing the Town of Sudbury's complaint seeking to prevent the Massachusetts Bay Transportation Authority (MBTA) from entering into an option agreement with Eversource Energy for an easement to install an electric transmission line underneath nine miles of a disused right of way (ROW), approximately 4.3 miles of which extend through the town, holding that the Town could not prevail on either of its claims.Here, the Town asked the Supreme Court to extend the common-law doctrine of prior public use and to determine that the doctrine barred the diversion of public land devoted to one public use to an inconsistent private use. The Supreme Judicial Court declined to adopt the Town's proposed reworking of the doctrine, holding that the Land Court judge did not err in dismissing the Town's complaint because (1) Eversource's proposed use of the MBTA ROW to construct and operate underground transmission lines is not a public use; and (2) the Town has not demonstrated that the benefits of expanding the prior public use doctrine to encompass subsequent inconsistent private uses outweigh the value of adhering to this Court's longstanding common-law formulation. View "Town of Sudbury v. Massachusetts Bay Transportation Authority" on Justia Law

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The Supreme Judicial Court vacated the judgment of the trial court granting summary judgment on several claims against police officers personally, holding that there was a genuine issue of material fact whether the police officers used excessive force against Appellant after he was removed from his vehicle.Plaintiff, a black man, was stopped by two police officers. The stop escalated into a physical altercation during which five police officers forcibly removed Plaintiff from the vehicle and wrestled him to the ground. Plaintiff was convicted of several offenses stemming from the incident. While the criminal case was pending, Plaintiff filed a civil action alleging that the officers committed several torts and violated his civil rights. The trial court granted summary judgment for Defendants on the civil action. The Supreme Judicial Court vacated the judgment in part, holding (1) Plaintiff's civil action may only proceed where it is based on facts beyond those that were necessary to sustain Plaintiff's prior criminal conviction and where Plaintiff demonstrates that his claims would not necessarily challenge the validity of his prior criminal conviction; and (2) this conclusion does not bar the claims that Plaintiff based on events that occurred after the police officers forcibly removed him from his vehicle. View "Tinsley v. Town of Framingham" on Justia Law

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The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence obtained as a result of a stop, holding that, going forward, the age of a juvenile suspect, if objectively apparent to a reasonable officer, will be part of the totality of the circumstances relevant to whether the juvenile as seized under article 14 of the Massachusetts Declaration of Rights.Minutes after a shooting, two police officers encountered seventeen-year-old Defendant walking on the sidewalk. After attempting to speak with Defendant, one of the officers started to get out of the cruiser, after which Defendant ran. Defendant was charged with murder in the first degree. Defendant filed a motion to suppress. The trial court denied the motion. The Supreme Judicial Court affirmed, holding (1) the trial judge did not abuse his discretion in concluding that the officers had a reasonable, articulable suspicion of criminal activity; (2) a child's age, when known to the officer or objectively apparent to a reasonable officer, is relevant to the question of seizure under article 14; and (3) there was insufficient evidence that the officers knew or should have known prior to his arrest, that Defendant was below the age of eighteen. View "Commonwealth v. Evelyn" on Justia Law

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The Supreme Judicial Court established a revised test for a court to determine whether a defendant seeking to suppress evidence based on a claim that a traffic stop violated equal protection principles.The Supreme Judicial Court reversed the judgment of the district court denying Defendant's motion to suppress the evidence seized from the vehicle he was driving, holding that the trial judge abused his discretion in denying the motion to suppress because Defendant produced sufficient evidence to raise a reasonable inference that the stop was racially motivated. In so holding, the Court concluded (1) a defendant seeking to suppress evidence evidence based on a violation of his or her equal protection rights must establish a reasonable inference that the officer's decision to initiate the stop was motivated by race or another protected class; and (2) to raise this inference, the defendant must point out specific facts from the totality of the circumstances surrounding the stop. View "Commonwealth v. Long" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on theories of deliberate premeditation and felony murder, holding that the trial court did not err in denying Defendant's motion to suppress or in introducing at trial Defendant's statements made to investigators.On appeal, Defendant argued that the trial court erred by denying his motion to suppress all the statements he made to investigators while he was questioned at a police station and that the admission of those statements at trial was prejudicial. The Supreme Judicial Court affirmed and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or to order a new trial, holding (1) the motion judge did not err in denying Defendant's motion to suppress; (2) the trial court did not err in admitting Defendant's statements at trial; and (3) no other relief was appropriate. View "Commonwealth v. Weidman" on Justia Law

Posted in: Criminal Law
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The Supreme Judicial Court affirmed Defendant's conviction, after a second jury trial, as a joint venturer in vaginal and anal rapes committed by his two coventurers, holding that subjecting Defendant to a second trial did not violate the constitutional protection against double jeopardy.Defendant was indicted on nine counts of forcible rape of a child. Defendant was charged as a principal in three of the rape counts and a joint venturer in three other counts. After a jury trial, Defendant was acquitted on the counts in which he was charged as a principal and all counts alleging oral rape where he had been charged as a joint venturer. The jury was unable to reach a verdict with respect to the remaining counts. At the retrial, the Commonwealth introduced the results of additional DNA tests conducted on the clothing the victim had been wearing. After a second jury trial, Defendant was convicted as a joint venturer in vaginal and anal rapes. The Supreme Judicial Court affirmed the convictions, holding (1) there was no error in retrying Defendant; and (2) the additional DNA evidence should not have been introduced at the second trial, but the error did not prejudice Defendant. View "Commonwealth v. Adams" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that there was no basis to set aside or reduce the verdict of murder in the first degree or to order a new trial.Specifically, the Supreme Judicial Court held that the trial judge did not err by (1) refusing to suppress Defendant's statements to police; (2) ruling against Defendant on two juror challenges pursuant to Commonwealth v. Soares, 377 Mass. 461 (1979); (3) excluding third-party culprit evidence; and (4) declining to instruct the jury in accordance with Commonwealth v. Reid, 29 Mass. App. Ct. 537 (1990). View "Commonwealth v. Rosa-Roman" on Justia Law

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The Supreme Judicial Court affirmed the order of the trial judge authorizing the disclosure to defense counsel of a discovery letter written by a district attorney describing misconduct by Petitioners, two police officers, that the district attorney obtained through immunized grand jury testimony, holding that the district attorney had a Brady obligation to disclose the exculpatory information to certain unrelated criminal defendants.The district attorney learned through a witness's immunized grand jury testimony that Petitioners knowingly made false statements in police reports that concealed the unlawful use of force by a fellow officer against an arrestee and supported a fake criminal charge of resisting arrest against the arrestee. The district attorney prepared a discovery letter describing Petitioners' misconduct and asked a superior court judge to authorize its disclosure to defense counsel as potentially exculpatory information in unrelated criminal cases where Petitioners might be witnesses. The superior court judge authorized the disclosure. The Supreme Judicial Court affirmed, holding that the prosecutors had a Brady obligation to disclose the exculpatory information to unrelated criminal defendants in cases where a petitioner is a potential witness or prepared a report in the criminal investigation even though that information was obtained in immunized grand jury testimony. View "In re Grand Jury Investigation" on Justia Law

Posted in: Criminal Law
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In these consolidated cases, the Supreme Judicial Court held that a delay in providing counsel to Defendants did not entitle them to release from pretrial detention under Lavallee v. Justices in the Hampden Superior Court, 442 Mass. 228 (2004).At Defendants' arraignments, the Commonwealth moved for both of them to be detained before trial pursuant to Mass. Gen. Laws ch. 276, 58A. Both defendants were entitled to appointed counsel for their section 58A hearings because they were found to be indigent. However, due to a shortage of available defense attorneys, there was a delay in the assignment of counsel for Defendants, and their section 58A hearings were continued. When the hearings took place, the judge set bail. Because neither defendant was able to post the required amount both were held in lieu of bail. Defendants filed petitions pursuant to Mass. Gen. Laws ch. 211, 3, arguing that they were entitled to release because their pretrial detention without counsel for more than seven days violated the standards established for timely appointment of defense counsel for indigent criminal defendants in Lavallee. The Supreme Judicial Court denied relief, holding that Lavallee did not create an automatic right to release from pretrial detention for any indigent defendant held more than seven days without counsel. View "Walsh v. Commonwealth" on Justia Law

Posted in: Criminal Law