Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Civil Rights
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The Supreme Judicial Court affirmed the judgment of the district court denying Defendant's motions to suppress, holding that the limited use of automatic license plate readers (ALPRs) in this case did not implicate constitutional protections against unreasonable searches. While police were investigating Defendant on suspicion of drug distribution they used ALPRs on two bridges to track Defendant's movements. The police accessed historical data via ALPR technology and received real-time alerts, the last of which led to Defendant's arrest. Defendant filed motions to suppress the ALPR data and the fruits of the arrest. The superior court denied the motions. The Supreme Judicial Court affirmed, holding that while the widespread use of ALPRs in the Commonwealth could implicate a defendant's constitutional protected expectation of privacy in the whole of his public movements, that interest was not invaded by the limited extent and use of the ALPR data in the instant case. View "Commonwealth v. McCarthy" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions and sentences for assault and battery on a family or household member and assault by means of a dangerous weapon, holding that that a trial judge may order a defendant to pay restitution to a third party in certain circumstances. On appeal, Defendant argued that her right to a fair trial was violated and that the trial judge erred in ordering her to pay restitution to the victim's mother, who was a third party and non victim. The Supreme Judicial Court affirmed, holding (1) Defendant received a fair trial; and (2) a trial judge may order a defendant to pay restitution to a third party, and the order in the instant case satisfied the causation requirement. View "Commonwealth v. McGann" on Justia Law

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The Supreme Judicial Court affirmed the order of the trial judge granting Defendant's motion to suppress certain GPS location data and its fruits, holding that the initial imposition of a GPS device as a condition of pretrial release violated article 14 of the Massachusetts Declaration of Rights. In 2015, Defendant was charged with possession of a class B substance with the intent to distribute, as a subsequent offense, and motor vehicle violations. Defendant was ordered to wear a GPS monitoring device as a condition of release. Defendant was later arrested and indicted on charges of armed robbery while masked. Defendant moved to suppress the GPS location data used to identify him as being present at the scene of the crime. After finding that Defendant had consented to the use of GPS location data only for the purposes of enforcing conditions of release and not for general law enforcement purposes the judge concluded that the search was not supported by probable cause and granted the motion to suppress. The Supreme Judicial Court affirmed on different grounds, holding that the search was impermissible because the GPS monitoring did not further any legitimate governmental interests. View "Commonwealth v. Norman" on Justia Law

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The Supreme Judicial Court affirmed the order of the motion judge allowing Defendant's motion to suppress evidence derived from the warrantless seizure and search of his cell phone, holding that the seizure of the cell phone was proper but the search of the cell phone was not proper. The trial court granted the motion to suppress on grounds that the seized cell phone was not properly handled pursuant to a valid written inventory policy and that the police had conducted an investigatory search of the seized cell phone. The Supreme Judicial Court affirmed, holding (1) it was permissible to seize the cell phone as part of a search incident to custodial arrest; and (2) the search exceeded the scope of, and was inconsistent with, the purposes underlying the search exception to the warrant requirement. View "Commonwealth v. Barillas" on Justia Law

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The Supreme Judicial Court reversed the judgment of the trial court and set aside Defendant's conviction as a joint venturer of murder in the first degree on the theory of extreme atrocity or cruelty, holding that the evidence presented to the jury was insufficient to establish Defendant's knowing participation in the murder with the required intent beyond a reasonable doubt. At the close of all evidence, Defendant moved for a required finding of not guilty. The motion was denied. After Defendant was convicted, he appealed, arguing that the trial judge erred in denying his motion for a required finding of not guilty. The Supreme Judicial Court agreed, holding (1) the Commonwealth's evidence was insufficient to demonstrate beyond a reasonable doubt Defendant's presence when the victim was stabbed, and therefore, the conviction cannot stand; and (2) retrial of Defendant was barred by the principles of double jeopardy. View "Commonwealth v. Lopez" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court allowing Defendant's motions to suppress evidence seized during an inventory search of his vehicle and his subsequent statements to police, holding that, where officers are aware that a passenger lawfully could assume custody of a vehicle, it is improper to impound the vehicle without first offering this option to the driver. Defendant, the driver of the vehicle in this case, was properly stopped for a motor vehicle violation and then arrested on an outstanding warrant. The vehicle's sole passenger was a duly licensed and qualified driver. The officers arranged for the vehicle to be impounded without inquiring of Defendant as to whether he preferred to have the passenger take custody of and move the vehicle. After conducting an inventory search the officers discovered Defendant's gun. The motion judge suppressed the gun and Defendant's statements, finding the impoundment to be unreasonable. The Supreme Judicial Court affirmed, holding that suppression was appropriate under the circumstances of this case. View "Commonwealth v. Goncalves-Mendez" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions entered by the trial court after a second trial, at which Defendant had different counsel, holding the second trial judge did not err in granting Defendant's motion for a new trial on the basis that Defendant's second attorney provided ineffective assistance of counsel. Defendant was charged with murder in the first degree and related offenses. Then the jury was unable to reach a verdict Defendant's first trial ended in a mistrial. The second trial resulted in Defendant being convicted. Defendant then filed a motion for a new trial, arguing that successor counsel's failure to call or investigate an alibi witness constituted constitutionally ineffective assistance of counsel. The second trial judge allowed the motion, determining that the testimony necessarily would be important to the jury's deliberations. The Supreme Judicial Court affirmed, holding that, under the circumstances, the judge was not unreasonable in finding successor counsel's performance ineffective, and the error was prejudicial. View "Commonwealth v. Diaz Perez" on Justia Law

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The Supreme Judicial Court affirmed the order of the motion judge allowing Defendant's motion to suppress, holding that both the patfrisk of Defendant and the search of Defendant's motor vehicle were improper. Two law enforcement officers approached Defendant's vehicle after observing that the vehicle had a cracked windshield and an expired inspection sticker. Defendant got out of his vehicle without being instructed to do so. The officers placed Defendant in handcuffs and conducted a patfrisk of his person. The officers subsequently seized a firearm from the floor in front of the driver's seat. Defendant filed a motion to suppress the evidence, which the motion judge granted. The Supreme Judicial Court reversed, holding (1) Defendant was properly stopped for motor vehicle violations; (2) Defendant's actions, without more, did not justify a patfrisk because they did not establish reasonable suspicion that Defendant was armed and dangerous; and (3) because the search of Defendant's motor vehicle was based on the results of the improper patfrisk, the vehicle search was unconstitutional. View "Commonwealth v. Torres-Pagan" on Justia Law

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The Supreme Judicial Court affirmed the judgment of the county court denying Defendant's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion in denying relief. Defendant was indicted on charges of murder in the first degree and other offenses. The trial judge declared a mistrial because the jury were unable to reach a verdict on the murder charge. Defendant moved to dismiss the murder indictment and for a required finding of not guilty, arguing that a retrial was barred by double jeopardy principles because there was insufficient evidence to warrant a conviction. The trial court denied the motion. Defendant then filed a Mass. Gen. Laws ch. 211, 3 petition seeking relief from the denial of that motion. The single justice denied relief. The Supreme Judicial Court affirmed, holding that double jeopardy principles did not bar Defendant's retrial on the murder charge because the Commonwealth presented sufficient evidence to warrant a conviction of murder in the first degree based on extreme atrocity or cruelty. View "Collazo v. Commonwealth" on Justia Law

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The Supreme Judicial Court affirmed the decision of the single justice dismissing Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3 challenging orders issued by the Land Court in connection with a servicemember proceeding under the Massachusetts Soldiers' and Sailors' Civil Relief Act (MSCRA), holding that the single justice properly dismissed the claims and defenses. In addition to his challenge to the orders issued in connection with the MSCRA action Petitioner also asserted affirmative defenses to foreclosure of his property and claims against Respondents under various statutes, common law, and rules of professional conduct. A single justice dismissed the petition, including all requests for relief. The Supreme Court affirmed, holding (1) Petitioner did not establish a substantial claim that the Land Court violated his substantial rights in connection with the servicemember proceeding; and (2) with respect to the other claims and affirmative defenses, Petitioner failed to demonstrate the absence of adequate alternative remedies. View "Marley v. Bank of New York" on Justia Law

Posted in: Civil Rights