Justia Massachusetts Supreme Court Opinion Summaries

In a joint trial, Markeese Mitchell, Pedro Ortiz, and Terrance Pabon were convicted of second-degree murder. Years later, they moved to interview a juror, alleging bias and concealment of material information during jury selection. The motion was denied, and the convictions were affirmed on appeal. Subsequently, the defendants filed motions for a new trial, citing additional evidence of the same juror's alleged bias. The motion judge conducted an evidentiary hearing, where the juror testified, and then denied the new trial motions. The defendants also moved to disqualify the trial judge, arguing a conflict of interest due to the judge's professional relationship with the prosecutor from their original trial, who had since become a Superior Court judge. This motion was also denied.The Appeals Court affirmed the orders denying the motions for a new trial and for disqualification. The Supreme Judicial Court granted further appellate review. The defendants argued that they were entitled to a new trial because the juror failed to provide an honest response to a material question during empanelment, and an honest response would have provided valid grounds for a challenge for cause. They also argued that the trial judge should have been disqualified due to a conflict of interest.The Supreme Judicial Court concluded that the trial judge did not abuse her discretion in denying the motions for a new trial or the motion for disqualification. The Court found that the juror's inaccurate answer was not dishonest and did not demonstrate bias. The Court also found that the trial judge's professional relationship with the former prosecutor did not create an appearance of partiality. Therefore, the orders denying the motions for a new trial and for disqualification were affirmed. View "Commonwealth v. Mitchell" on Justia Law

Two children in the custody of the Department of Children and Families (DCF) appealed the dismissal of guardianship petitions filed by their great-aunt and great-uncle, who reside in Pennsylvania. The Juvenile Court dismissed the petitions, citing the Interstate Compact on the Placement of Children (ICPC), as Pennsylvania had denied the placement due to the great-uncle's felony convictions from the 1990s. The children argued that the ICPC does not apply to out-of-state relatives seeking guardianship, while DCF contended that the appeal should be dismissed because the great-aunt and great-uncle, who are indispensable parties, did not appeal the dismissal.The Juvenile Court granted DCF's motion to dismiss the guardianship petitions, concluding that allowing the guardianship would violate the ICPC. The court noted that Pennsylvania's denial was based on the great-uncle's ineligibility to work or volunteer with children due to his felony convictions. The children filed a motion for reconsideration, which was denied. They then filed timely notices of appeal, but the great-aunt and great-uncle did not.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the absence of the great-aunt and great-uncle, who are indispensable parties, compelled the dismissal of the appeal. The court emphasized that it could not proceed without the relatives, whose rights would be affected by the decision. Consequently, the appeal was dismissed. View "Guardianship of Wilson" on Justia Law

A child was temporarily removed from her parents' care shortly after birth and placed in the custody of the Department of Children and Families (DCF) due to concerns about domestic violence. DCF sought to vaccinate her according to an age-based immunization schedule, but her parents, practicing Rastafarians, objected on religious grounds. A Juvenile Court judge allowed DCF to facilitate vaccinations for the child. The parents sought to stop future vaccinations, arguing that vaccinating their child over their religious objections violated their constitutional rights.The Juvenile Court judge found that the parents' religious beliefs were outweighed by the child's best interests and allowed DCF to vaccinate the child. The parents petitioned the Appeals Court for interlocutory relief, which was denied. The parents then appealed to the Appeals Court panel, and the child sought direct appellate review in the Supreme Judicial Court, which was granted.The Supreme Judicial Court of Massachusetts held that the order allowing the child to be vaccinated violated the parents' constitutional rights. The court concluded that the parents' sincerely held religious beliefs were substantially burdened by DCF's vaccination efforts. The court applied the State constitutional protections afforded to parents exercising their free exercise rights and determined that DCF failed to demonstrate that exempting the child from vaccinations would substantially hinder the fulfillment of DCF's interests in promoting child health. The court noted the Commonwealth's allowance of religious exemptions from vaccination requirements for parents who have not lost custody and DCF's inconsistent exercise of its authority to order vaccinations for children in its care. The order allowing the joint motion by DCF and the child to facilitate the vaccination of the child was reversed. View "Care and Protection of Eve" on Justia Law

In the early morning of March 24, 2015, Kenneth Lopez was shot and killed on Dwight Street in Springfield. His body was discovered the next morning. Lee Manuel Rios was arrested nine days later and charged with murder, conspiracy to commit murder, and several firearms offenses. In February 2018, a jury convicted Rios of first-degree murder with extreme atrocity or cruelty and deliberate premeditation, sentencing him to life in prison without parole.Rios appealed his convictions, the denial of his motion to suppress mail intercepted by the jail, the denial of his posttrial motion for a new trial, and sought relief under G. L. c. 278, § 33E. He also sought a new trial on several firearms convictions in light of the decision in Commonwealth v. Guardado.The Massachusetts Supreme Judicial Court reviewed the case. The court found no reason to exercise its extraordinary power to grant a new trial or reduce Rios's conviction of first-degree murder. The court affirmed the murder conviction and other firearm offenses, as well as the orders denying his pretrial motion to suppress and posttrial motion for a new trial. However, the court vacated Rios's convictions under G. L. c. 269, § 10 (a) and (h) and remanded those charges for a new trial, in accordance with the decision in Guardado II. View "Commonwealth v. Rios" on Justia Law

The defendant was convicted by a jury of aggravated rape of a child and indecent assault and battery on a child under fourteen years old. The charges stemmed from the defendant's rape and sexual assault of his twelve-year-old granddaughter. The victim testified that the defendant assaulted her in his bedroom while her mother was out of the house. The victim reported the assault to a Department of Children and Families (DCF) social worker, which led to police involvement and the collection of DNA evidence from the bedding.The Superior Court admitted the DNA evidence, which confirmed the presence of the defendant's DNA but excluded the victim's DNA. The defense argued that the DNA evidence contradicted the victim's testimony and suggested that the victim fabricated the assault after seeing the defendant with his girlfriend. The jury convicted the defendant on all counts, and the defendant appealed.The Supreme Judicial Court of Massachusetts reviewed the case. The defendant argued that his confrontation rights were violated because a reviewing analyst testified about the findings of a nontestifying analyst concerning DNA testing. The court agreed that the testimony was admitted in error but concluded that the error did not result in a substantial risk of a miscarriage of justice. The court also addressed the defendant's argument that the judge abused his discretion in admitting evidence of a prior sexual assault by the defendant on the victim. The court found that the judge acted within his discretion in admitting the prior bad act evidence.The Supreme Judicial Court affirmed the judgments, holding that the admission of the DNA evidence and the prior bad act evidence did not warrant a new trial. The court concluded that the errors did not significantly impact the trial's outcome, given the overall strength of the victim's testimony and the limited nature of the prior bad act evidence. View "Commonwealth v. Nascimento-Depina" on Justia Law

The defendant crashed his vehicle into a State police cruiser parked in the breakdown lane on Interstate Route 90, resulting in the death of a trooper. The defendant was convicted of involuntary manslaughter, misdemeanor motor vehicle homicide by means of negligent or reckless operation, operating a motor vehicle so as to endanger the lives or safety of the public, and operating an uninsured motor vehicle. The defendant appealed, arguing that the Legislature did not authorize multiple punishments for involuntary manslaughter, motor vehicle homicide, and operating to endanger arising from the same act. He also contended that the evidence was insufficient to sustain his involuntary manslaughter conviction and that his trial counsel was ineffective.The Superior Court judge denied the defendant's motion for a new trial. The Appeals Court reversed the convictions of motor vehicle homicide and operating to endanger, holding that the Legislature did not intend to impose multiple punishments based on the same act for those offenses where a defendant is also convicted of involuntary manslaughter. The Appeals Court upheld the involuntary manslaughter conviction and rejected the defendant's arguments regarding the insufficiency of evidence and ineffective assistance of counsel.The Supreme Judicial Court of Massachusetts granted further appellate review. The court reaffirmed its holding in Commonwealth v. Jones, which precludes multiple punishments for involuntary manslaughter, motor vehicle homicide, and operating to endanger based on the same act. The court affirmed the defendant's convictions of involuntary manslaughter and operating an uninsured motor vehicle but reversed the convictions of motor vehicle homicide and operating to endanger. The court also affirmed the denial of the defendant's motion for a new trial, finding no ineffective assistance of counsel. View "Commonwealth v. Njuguna" on Justia Law

In this case, the defendant was convicted of first-degree murder. The incident occurred on February 6, 2006, when the victim was shot multiple times in an apartment building. Several witnesses, including Corrin Cripps, Jeanette Martinez, and Michael Gomes, identified the defendant as the shooter. Cripps and Martinez were using cocaine at the time of the incident, and Gomes initially failed to identify the defendant in a photographic array. The defendant was later found in Puerto Rico, where he provided an alias to the police.The defendant's conviction was previously affirmed by the Supreme Judicial Court of Massachusetts, along with the denial of his first motion for a new trial. In November 2022, the defendant filed a second motion for a new trial, arguing that newly discovered evidence regarding the unreliability of eyewitness identifications entitled him to a new trial. This motion was denied by a Superior Court judge, and the defendant sought leave to appeal from a single justice of the Supreme Judicial Court, which was granted on the issue of the new eyewitness identification science.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the denial of the second motion for a new trial. The court agreed that the new research on eyewitness identification was indeed newly discovered evidence. However, it concluded that this new evidence would not have been a real factor in the jury's deliberations. The court noted that the new research primarily addressed the unreliability of stranger identifications, which was only relevant to one of the three eyewitnesses. Additionally, the jury had already been made aware of the potential issues with the eyewitness identifications through cross-examination. The court also pointed out that there was other evidence of the defendant's guilt, including his intent and consciousness of guilt demonstrated by his actions after the shooting. Therefore, the court held that the absence of the new evidence did not cast real doubt on the justice of the conviction. View "Commonwealth v. Mercado" on Justia Law

In August 2021, five defendants responded to online advertisements offering sexual services for a fee. The advertisements, posted by undercover police officers, depicted an adult woman and listed various sexual services. Each defendant contacted the purported sex worker, selected services, agreed to the set price, and went to the specified location. Upon arrival, they were arrested by police officers.A Plymouth County grand jury indicted each defendant for trafficking of persons for sexual servitude under G. L. c. 265, § 50, and engaging in sexual conduct for a fee under G. L. c. 272, § 53A. The defendants moved to dismiss the sex trafficking charges, arguing that the facts did not support probable cause. A Superior Court judge allowed the motions, reasoning that the defendants did not attempt to traffic "another person" since the sex worker was an undercover officer. The Commonwealth appealed, and the Appeals Court affirmed the dismissal, concluding that the evidence did not constitute trafficking of a person for sexual servitude. The Commonwealth then sought further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the dismissal of the sex trafficking indictments. The court held that the defendants' conduct of responding to advertisements, agreeing to terms, and going to the location did not constitute "trafficking of persons for sexual servitude" under G. L. c. 265, § 50. The court concluded that the statute did not apply to purchasers who respond to offers from independent sex workers and accept the terms set by the sex worker. The court emphasized that the statute targets those involved in the operation of sex trafficking schemes, not the subset of purchasers targeted by the sex for a fee statute. The case was remanded for further proceedings on the remaining indictments. View "Commonwealth v. Garafalo" on Justia Law

Two detectives from the Lowell police department, while investigating a home invasion in Lowell, Massachusetts, crossed into Nashua, New Hampshire, to speak with the defendant. During the conversation, one detective suspected the defendant was deleting data from his cell phone and seized it without a warrant. The detectives then brought the phone back to Massachusetts and obtained a warrant to search it.In the Superior Court, the defendant moved to suppress the evidence obtained from the cell phone, arguing that the seizure was unlawful. The motion judge allowed the motion, finding that the Lowell detectives had no authority to seize the phone in New Hampshire. The Commonwealth sought an interlocutory appeal, which was allowed by a single justice of the Supreme Judicial Court for the county of Suffolk. The case was then transferred to the Supreme Judicial Court on its own initiative.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the Lowell detective did not have extraterritorial authority to seize the cell phone in New Hampshire. The court found that no statutory or common law authority permitted the warrantless seizure in these circumstances. The court also rejected the Commonwealth's argument that the evidence would have been inevitably discovered, as this theory was not sufficiently supported by the record. The court held that suppression of the evidence was the appropriate remedy to deter police misconduct and preserve judicial integrity. The order allowing the motion to suppress was affirmed. View "Commonwealth v. McCarthy" on Justia Law

A child was born on May 30, 2017, to unmarried parents. The mother, A.D., believed Q.T. was the father, and he signed a Voluntary Acknowledgment of Parentage (VAP) on June 1, 2017. However, a DNA test on July 6, 2017, revealed Q.T. was not the biological father. Despite this, the VAP was not rescinded within the statutory period, and Q.T. ceased contact with the child. Years later, the mother identified K.S. as the potential biological father through a DNA testing platform and filed multiple complaints to establish K.S. as the legal father.The Middlesex Division of the Probate and Family Court initially dismissed the mother’s complaints due to procedural issues and the existing VAP. However, after consolidating the sixth and seventh complaints, the court ordered genetic marker testing, which confirmed K.S. as the biological father. The court then rescinded the VAP, declared K.S. the legal father, and ordered changes to the child’s birth certificate.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the Probate and Family Court judge lacked the authority to override the statutory deadlines for rescinding a VAP. The statute of repose under G. L. c. 209C, § 11(a), establishes strict time limits for challenging a VAP, which had long expired in this case. The court emphasized the legislative intent to provide finality in parentage determinations for the stability and security of the child. Consequently, the Supreme Judicial Court vacated the lower court’s judgments and remanded the case for proceedings consistent with its opinion. View "A.D. v. K.S." on Justia Law