Justia Massachusetts Supreme Court Opinion Summaries

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

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

In the case of Commonwealth v. Rashad Shepherd, the Supreme Judicial Court of Massachusetts affirmed the defendant’s conviction of murder in the first degree on the theory of felony-murder, with attempted unarmed robbery as the predicate felony. The case centered around a failed robbery attempt that ended in the shooting and death of the intended victim. The defendant, along with two co-conspirators, hatched a plan to rob the victim, who was known to sell marijuana from his apartment. However, when the plan was put into motion, the victim resisted, and in the ensuing altercation, was shot and killed. The prosecution's theory was that the defendant was the shooter.In his appeal, the defendant argued that the court’s decision in a prior case, Commonwealth v. Brown, which abolished felony-murder as an independent theory of liability for murder in the first and second degrees, should be applied to his case retroactively. He maintained that not doing so violated equal protection principles as more Black individuals were serving life sentences without parole for felony-murder than white individuals. However, the court rejected this argument, noting that the decision in Brown was applied to all equally, regardless of race or ethnicity.The defendant also claimed errors in jury instructions and conduct by the trial judge, but the court determined that there was no reversible error. Lastly, the defendant argued that he received ineffective assistance of counsel, but the court found that the decisions by the defense were not manifestly unreasonable. View "Commonwealth v. Shepherd" on Justia Law

In this case, six plaintiffs -- two criminal defense organizations, two defense attorneys, and two former criminal defendants -- filed a petition against the District Attorney's Office for the Hampden District in Massachusetts. The plaintiffs alleged multiple failures by the District Attorney's Office, primarily stemming from its handling of evidence of misconduct within the Springfield Police Department (the department). The U.S. Department of Justice had previously conducted an investigation and found that officers in the department, particularly those within the narcotics bureau, routinely falsified police reports and engaged in a pattern of excessive force.The Supreme Judicial Court of Massachusetts found that the District Attorney's Office, through certain discovery policies, committed a breach of both the duty to disclose evidence that tends to exculpate defendants and the duty to investigate or inquire about such evidence. Specifically, the court identified three problematic practices: 1) disclosing adverse credibility findings made about the department's officers only on a discretionary basis; 2) withholding instances of officer misconduct from disclosure where a specific bad act cannot be clearly attributed to a particular officer; and 3) failing to gain access to all documents known to have been reviewed by the Department of Justice (DOJ).To rectify these breaches, the court ordered the District Attorney's Office to obtain access to all categories of documents known to have been reviewed by the DOJ and disclose them to the plaintiffs. From there, case-by-case adjudication can begin to address the claims of individual defendants affected by the department's misconduct. In issuing this order, the court emphasized the importance of a prosecutor's dual duties -- to disclose and to investigate -- in upholding the integrity of the criminal justice system. View "Graham v. District Attorney for the Hampden District" on Justia Law

In a case before the Supreme Judicial Court of Massachusetts, the defendant, Denzel McFarlane, convicted of unlawful possession of a firearm and other related charges, appealed for a new trial. He based his appeal on the fact that a police officer who had arrested and testified against him was found civilly liable for false arrest and false imprisonment in an unrelated lawsuit. McFarlane argued that the existence of the civil lawsuit against the officer was exculpatory information that the prosecution should have disclosed to the defense but failed to do so.The primary legal issue was whether the existence of a pending civil lawsuit against a police officer must be disclosed by a prosecutor as exculpatory evidence. The court held that the existence of a pending civil lawsuit against a police officer does not need to be disclosed by a prosecutor as exculpatory evidence. The court reasoned that until a finding of liability has been made, a pending civil lawsuit constitutes an unsubstantiated allegation of police misconduct that does not tend to negate the guilt of the defendant. Therefore, the court affirmed the denial of McFarlane's motion for a new trial.In addition, the court established that while a prosecutor has no duty to inquire into pending civil lawsuits against a prosecution team member, the duty of inquiry does require that prosecutors inquire about the existence of any findings of civil liability related to the performance of a police officer's duties. In other words, if a police officer has been found liable in a civil lawsuit, the prosecution has a duty to discover that information and potentially disclose it to the defense. View "Commonwealth v. Mcfarlane" on Justia Law

In the case at hand, the plaintiff, a civilly committed sexually dangerous person, petitioned the Department of Correction (DOC) for medical parole due to his deteriorating health conditions. The DOC denied his petition based on their policy that civilly committed individuals are ineligible for medical parole under G. L. c. 127, § 119A. The plaintiff sought review of this denial, arguing that his due process rights had been violated. A Superior Court judge allowed his motion for judgment on the pleadings and ordered the DOC to conduct a hearing on the plaintiff's medical parole petition.However, the Supreme Judicial Court of Massachusetts reversed the judge's order. The court held that the medical parole statute applies only to committed offenders serving a criminal sentence, not to civilly committed sexually dangerous persons. It further held that sexually dangerous persons may seek release due to terminal illness or physical or mental incapacity under G. L. c. 123A, § 9, and denying them an additional avenue for relief by means of the medical parole statute does not offend substantive due process. The Court concluded that the plaintiff's due process rights were not violated by the DOC's policy that precludes civilly committed sexually dangerous persons from eligibility for medical parole. View "Murphy v. Commissioner of Correction" on Justia Law

In the case at hand, the defendant, Joshua Hart, and his girlfriend, Brittany Smith, entered the home of an elderly couple, Thomas Harty and his wife, Joanna Fisher, intending to steal their car and money. The couple ended up fatally attacking both Harty and Fisher, and then fled the state in the victims' vehicle. Hart was convicted on two counts of first-degree murder, and he appealed on several grounds.Hart argued that his confession to law enforcement was involuntary and should have been suppressed, but the Supreme Judicial Court of Massachusetts disagreed. The court found that Hart's confession was voluntary based on the circumstances of the interrogation, his experience with the criminal justice system, and his own actions and statements during the interrogation.Hart also argued that the trial should have been moved to another venue due to pretrial publicity. The court disagreed, stating that the defendant did not provide sufficient evidence to demonstrate that the pretrial publicity caused either presumptive or actual prejudice. The court found that less than 20% of potential jurors were excused due to pretrial publicity, and the judge took extensive steps to protect Hart's right to a fair trial.Hart further contended that a statement made by the deceased victim, Fisher, to her nurse, which was relayed to the jury through the nurse's testimony, should have been excluded from evidence as it was hearsay and violated his right to confront witnesses. The court determined that Fisher's statements were non-testimonial and thus did not violate the confrontation clause. The court also found that even if Fisher's statements were admitted in error, there was no prejudice because the Commonwealth presented other compelling evidence of the facts relayed in Fisher's statements.Finally, Hart argued that his sentences of life without the possibility of parole constituted cruel or unusual punishment because he was under 25 years old at the time of the crimes. The court rejected this argument, finding no reason to extend the prohibition of life sentences without parole for juveniles to individuals under the age of 25.Accordingly, the court affirmed Hart's convictions. View "Commonwealth v. Hart" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree based on a theory of felony-murder, among other charges, holding that a police officer's identification testimony was admitted improperly, but its admission did not prejudice Defendant.On appeal, Defendant challenged the denial of his motion to suppress, among numerous other allegations of error. For the claimed errors, Defendant requested that the court reduce his verdict or order a retrial. The Supreme Judicial Court affirmed, holding (1) a police officer's testimony identifying Defendant in a video recording at trial was improperly admitted, but the admission did not prejudice Defendant; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Fisher" on Justia Law

In this case involving a facility that operated under the protection of a thirty-six-year-old consent decree the Supreme Judicial Court held that the trial judge did not abuse her discretion in concluding that the Department of Developmental Services failed to establish that the consent decree should be terminated based on the evidentiary record before the probate court.In question was the treatment and welfare of individuals who suffered from severe developmental and intellectual disabilities that caused them to engage in grievous self-harm and other life-threatening behaviors. The individuals lived in group homes under the care of Judge Rotenberg Educational Center, Inc. (JRC), a facility that employed the use of aversive interventions such as electric skin shock as part of its treatment approach. In the 1980s and 1990s State agencies disrupted JRC's operations, after which the consent decree was issued. Years later, the agencies bound by the decree moved for its termination, but the probate and family court denied the motion. The Supreme Judicial Court affirmed, holding that the Department's arguments against continued enforcement of the consent decree were unavailing. View "Judge Rotenberg Educational Center, Inc. v. Commissioner of Dep't of Developmental Services" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of assault and battery by means of a dangerous weapon, holding that portions of the victim's then-girlfriend's grand jury testimony were properly admitted in accordance with the hearsay exemption for prior inconsistent statements.Prior to trial, the victim's then-girlfriend Shyla Bizarro identified Defendant as the victim's attacker from surveillance video footage and testified to her identification before the grand jury. Prior to her testimony, however, Bizarro revealed that she wished to recant her statements to police and her grand jury testimony. The trial judge admitted substantively the recanted portions of Bizarro's grand jury testimony, including her prior statements of identification. The Supreme Judicial Court affirmed the conviction, holding (1) the portions of Bizarro's grand jury testimony were properly admitted as prior inconsistent statements; (2) portions of Bizarro's grand jury testimony identifying Defendant in the video independently satisfied the hearsay exemption for statements of identification; and (3) there was no merit to Defendant's remaining arguments. View "Commonwealth v. Brum" on Justia Law