Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in January, 2014
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After a jury trial, Defendant was convicted of murder in the first degree on a theory of extreme atrocity or cruelty. The Supreme Court reversed and remanded for a new trial. Defendant was tried again and was again convicted of murder in the first degree on a theory of extreme atrocity or cruelty. The Supreme Court vacated the murder conviction and remanded for entry of a verdict of murder in the second degree, holding that Defendant’s mental illness and impaired mental condition drove her behavior and materially affected the fairness of a conviction of murder in the first degree on a theory of extreme atrocity or cruelty and that the unusual circumstances of this case made a verdict of murder in the second degree more consonant with justice. View "Commonwealth v. Berry" on Justia Law

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After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty. The Supreme Court affirmed Defendant’s convictions and the denial of his motion for a new trial, holding (1) Defendant’s Sixth Amendment right to a public trial was not violated when the trial judge ordered that, before entering the court room, each spectator must sign in and give a source of identification to the court officer posted outside the court room; (2) the trial judge did not err by admitting into evidence grand jury testimony of a prosecution witness; (3) the admission of certain hearsay did not create a substantial likelihood of a miscarriage of justice; and (4) the trial judge did not violate Defendant’s right to be tried by an impartial jury by failing to conduct a voir dire of all the jurors after one juror expressed concern that Defendant had access to the juror’s address in the juror’s confidential questionnaire. View "Commonwealth v. Maldonado" on Justia Law

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Following a jury trial nearly three years after his initial arraignment, Defendant was convicted of disorderly conduct and assault by means of a dangerous weapon. The Supreme Court reversed Defendant’s convictions and dismissed the complaints against him, holding (1) Defendant was denied a speedy trial, and any failures by his trial counsel to perfect that claim constituted ineffective assistance of counsel; and (2) the trial judge’s order of restitution to compensate a police officer whose glasses were damaged during his interaction with Defendant was constitutional under Apprendi v. New Jersey and met the “causal connection” requirement for such awards under Commonwealth v. McIntyre. View "Commonwealth v. Denehy" on Justia Law

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Defendant was convicted of first degree murder on a theory of joint venture and sentenced to life in prison. Defendant appealed, arguing, among other things, that the trial judge erred in finding that he was not a target of the investigation, and because he was a target, the Commonwealth was required to advise him of his Fifth Amendment right to avoid self-incrimination. The Supreme Court affirmed, holding (1) the evidence was sufficient to permit a jury to find Defendant guilty of murder in the first degree; (2) the trial judge did not err in determining that Defendant was not a target of the investigation at the time of his grand jury testimony, but a new prospective rule requires the Commonwealth to advise targets or potential targets of the grand jury’s investigation of their right not to incriminate themselves; and (3) Defendant was not entitled to a DiGiambattista instruction where it was not requested at trial. View "Commonwealth v. Woods" on Justia Law

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The Attorney General issued four citations to Plaintiffs for failing to pay the prevailing wage to certain employees. Plaintiffs appealed the citations to the Division of Administrative Law Appeals (DALA) under Mass. Gen. Laws ch. 149, 27C(b)(4). Kimberly Fletcher, a DALA administrative magistrate, heard Plaintiffs’ appeal but resigned before DALA issued a decision on the appeal. Shelly Taylor, the chief administrative magistrate of DALA, subsequently reviewed Fletcher’s proposed decision and took over responsibility for deciding the appeal. The DALA then issued a decision on Plaintiffs’ appeal, which affirmed the fourth citation and vacated the first three. Fletcher’s and Taylor’s rationales for vacation differed, however. The superior court affirmed the DALA decision. The Supreme Court affirmed, holding (1) the superior court was correct in affirming the fourth citation; (2) the DALA chief administrative magistrate has the authority to review and approve a hearing officer’s decision in a section 27C(b)(4) appeal before a final opinion issues; and (3) under these circumstances, Taylor’s actions in completing the section 27C(b)(4) hearing and administrative decision process were appropriate. View "Lighthouse Masonry, Inc. v. Div. of Admin. Law Appeals" on Justia Law