Justia Massachusetts Supreme Court Opinion Summaries

by
The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of deliberate premeditation but vacated his conviction of murder in the first degree on a theory of felony-murder, holding that the felony-murder conviction was improper.Defendant was convicted of murder in the first degree on theories of deliberate premeditation and felony-murder, with aggravated kidnapping as the predicate felony. In this appeal, consolidated with the appeal of his motions for a new trial and for reconsideration, Defendant argued, and the Commonwealth conceded, that the conviction of murder in the first degree on a theory of felony-murder was improper because the predicate felony of aggravated kidnapping did not exist at the time of the killing. The Supreme Court vacated Defendant's felony-murder conviction and otherwise affirmed, holding (1) Defendant's conviction of felony-murder lacked sufficient evidence to support it; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Samia" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the county court denying Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner was awarded monetary damages after a jury trial on a breach of contract claim against Respondent. The appellate division affirmed. Petitioner later moved for the appointment of a special process server to conduct a sale of Respondent's real property in order to satisfy the amended judgment and execution. Thereafter, Respondent presented a check for the execution amount plus postjudgment interest. Petitioner refused to accept payment and continued to litigate its motion. A judge declined to take action and ordered that further accrual of postjudgment interest would be tolled. Petitioner moved to vacate the judge's tolling ruling, but the trial court declined to rule on the motion. Petitioner then filed this petition requesting relief from the tolling order. The single justice denied the petition. The Supreme Judicial Court affirmed, holding that Petitioner was not entitled to relief. View "Suburban Electric Contracting, Inc. v. Ozdemir" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the county court denying the Commonwealth's petition filed under Mass. Gen. Laws ch. 211, 3 seeking relief from a superior court judge's denial of the Commonwealth's motion to disqualify Rosemary Scapicchio, Defendant's appellate counsel, on the ground that she had a conflict of interest, holding that the single justice did not err or abuse his discretion in denying the motion.Defendant was convicted of murder in the first degree. Later, represented by Scapicchio, Defendant filed a motion for a new trial alleging ineffective of counsel. Thereafter, Scapicchio represented Michael Barros at a hearing in an unrelated criminal case. The Commonwealth moved to disqualify Scapicchio on the grounds that her representation of both Defendant and Barros gave rise to a conflict of interest. The superior court denied the motion. The Commonwealth then filed the petition at issue. The single justice denied relief without reaching its merits. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused his discretion by denying the petition. View "Commonwealth v. Monteiro" on Justia Law

by
The Supreme Judicial Court affirmed the order of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that nothing in Petitioner's petition required exercise of the court's extraordinary power of general superintendence.Petitioner, who was indicted for murder in the first degree and related offenses, filed a document entitled "Notice of Default and Opportunity to Cure re affidavit -- 'Writ of Quo Warranto' re Proof of Claim/Jurisdiction'" claiming that the courts of the Commonwealth lacked jurisdiction over him. The superior court judge denied the petition. Thereafter, Petitioner brought this petition seeking review. A single justice denied the petition. The Supreme Judicial Court affirmed, holding that the single justice was warranted in denying this Mass. Gen. Laws ch. 211, 3 petition. View "Wallace v. Commonwealth" on Justia Law

Posted in: Criminal Law
by
The Supreme Judicial Court affirmed Defendant's conviction of one count of murder in the first degree on the theories of deliberate premeditation, extreme atrocity or cruelty, and felony murder, holding that there was no prejudicial error or reason to grant relief under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in finding Defendant competent to stand trial over defense counsel's objections; (2) Defendant was not prejudiced by the jury instructions concerning the consequences of a verdict of not guilty due to lack of criminal responsibility; and (3) the jury were entitled to conclude that Defendant was criminally responsible, and this Court declines to reduce the degree of guilt, order a new trial, or grant other relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Beatty" on Justia Law

Posted in: Criminal Law
by
In this case considering whether an easement (2018 easement) taken by eminent domain by the Department of Transportation (MassDOT) exceeded the scope of an easement taken in 1991 by the Department of Public Works (DPW), MassDOT's predecessor in interest, with respect to Plaintiff's land in South Boston (burdened land), the Supreme Judicial Court held that summary judgment was improperly granted for MassDOT.DPW's 1991 order of taking created an easement over the burdened land for purposes of constructing a haul road. In 2017, the Massachusetts Bay Transportation Authority began planning the construction of a test track on a portion of Plaintiff's land burdened by the 1991 easement. MassDOT recorded the 2018 confirmatory order of taking and then, contending that the taking merely confirmed that rights it held under the 1991 taking, refused to pay Plaintiff any compensation. Plaintiff responded with this litigation, and the superior court judge entered summary judgment in favor of MassDOT. The Supreme Judicial Court reversed, holding (1) while the intent of the parties should not be considered when an easement is taken by eminent domain, the ordinary rules of interpretation for easements otherwise apply; and (2) because the 1991 easement was more limited in scope than the 2018 easement, summary judgment for MassDOT must be reversed. View "Smiley First, LLC v. Dep't of Transportation" on Justia Law

by
The Supreme Judicial Court held that a defendant who has been serving the incarcerated portion of an illegal sentence imposed by the appellate division of the superior court has the same double jeopardy protections as a defendant who has been serving the incarcerated portion of an illegal sentence imposed by a single superior court judge.Defendant was convicted of indecent assault and battery. The appellate division revised Defendant's sentence by reducing the period of incarceration on two counts to from four to six years in prison. After it was discovered that Defendant's sentence was illegal the appellate division reversed the incarcerated portion of Defendant's sentence to concurrent terms of from five to six years. Defendant filed a petition under Mass. Gen. Laws ch. 211, 3 arguing that his resentence violated common-law principles of double jeopardy. The single justice denied the petition. The Supreme Judicial Court reversed, holding (1) when sufficient time has lapsed even an illegal sentence becomes final, and double jeopardy principles preclude the State from making upward adjustments to the sentence; and (2) Defendant was entitled to judgment on his petition. View "Martin v. Commonwealth" on Justia Law

Posted in: Criminal Law
by
In this action brought by the Commonwealth seeking relief from a trial court order requiring it to disclose information regarding a confidential informant the Supreme Judicial Court held that the motion judge in this case abused her discretion by failing to conduct the two-stage inquiry applicable to motions for disclosure of information subject to the Commonwealth's assertion of the informant privilege.After an informant notified police that Defendant was dealing crack cocaine Defendant was charged with a drug-trafficking offense and unlicensed operation of a motor vehicle. Defendant moved for disclosure of the name and address of the informant, as well as details relating to the informant's credibility. The motion judge allowed the motion. The Supreme Judicial Court reversed, holding that (1) the motion judge abused her discretion by failing to conduct the two-stage inquiry applicable to motions for disclosure of information subject to the Commonwealth's assertion of the informant privilege; and (2) the information sought was not sufficiently material or relevant to the defense to warrant the Commonwealth's assertion of the privilege. View "Commonwealth v. Gandia" on Justia Law

Posted in: Criminal Law
by
The Supreme Judicial Court remanded this case to the county court for entry of a judgment reversing the order of the motion judge allowing Defendant's motion for discovery and requiring the Commonwealth to disclose information about a confidential informant, holding that the Commonwealth's invocation of the informant privilege was proper. In obtaining a search warrant that led to the seizure of firearms from Defendant's apartment and Defendant's ensuing arrest on firearms and ammunition charges, the Commonwealth relied on information from the informant at issue. After he was charged, Defendant filed a motion seeking discovery of offers made to the informant and documents related to the informant's participation in other criminal investigations. The motion judge allowed the motion. The Supreme Judicial Court reversed, holding that the motion judge abused her discretion in granting the motion because the requested information would effectively disclose the informant's identity and Defendant failed to show that the informant was relevant and material to her defense. View "Commonwealth v. Whitfield" on Justia Law

Posted in: Criminal Law
by
The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion by denying relief.Petitioner alleged in his petition that a number of State actors had been engaged in "deliberately child-predatory and subversionary public nuisance activities" in furtherance of a conspiracy against him. The single justice denied relief. The Supreme Judicial Court affirmed and took measures intended to prevent Petitioner from further abusing the system, holding that the single justice was not obligated to exercise the court's superintendent power to become involved in this matter. View "Kifor v. Commonwealth" on Justia Law

Posted in: Civil Rights