Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of unlawful distribution of heroin as a subsequent offender and unlawful possession of heroin with intent to distribute as a subsequent offender, holding that the superior court did not err by denying Defendant's motion to suppress and that there was no other error.In his suppression motion, Defendant sought to suppress evidence found during a warrantless search of a motor vehicle. The superior court denied the motion to suppress. The Supreme Judicial Court affirmed the denial of the suppression motion and Defendant's convictions, holding (1) the police had probable cause to search the vehicle, and there was no error in the denial of the motion to suppress; (2) the trial judge erred in allowing the admission of an in-court identification made by a police officer, but the error did not prejudice Defendant; and (3) there was no substantial risk of a miscarriage of justice as to the jury instructions on possession and distribution of narcotics. View "Commonwealth v. Ortiz" on Justia Law

In this appeal from various orders regarding Defendant's pretrial detention status the Supreme Judicial Court vacated the decision of the single justice concluding that no due process violation occurred regarding one case and ruled that the other case was moot, holding that remand was required for a determination as to whether Defendant's continued pretrial confinement violates due process.Defendant had been held in pretrial detention for more than eighteen months on charges arising out of the Chelsea Division and the Lynn Division of the District Court Department. At the time of this opinion, Defendant had been held for over a year beyond his initial trial dates. Defendant was eventually acquitted of the charges in the Chelsea case. In the Lynn case, Defendant's trial was delayed due to the COVID-19 pandemic. At issue was whether the prolonged detention violated Defendant's due process rights. The Supreme Judicial Court held (1) in analyzing whether a defendant's pretrial detention violates due process this opinion contains a procedural framework; (2) because Defendant was acquitted in the Chelsea case, that case was moot; and (3) as to the Lynn case, the matter must be remanded for further proceedings. View "Mushwaalakbar v. Commonwealth" on Justia Law

The Supreme Judicial Court vacated the decision of the superior court judge allowing Defendant's motion to suppress, holding that Defendant enjoyed no reasonable expectation of privacy in the text messages sent by him that were stored on a cellular telephone belonging to, and possessed by, another person.Defendant and six codefendants were indicted on charges of trafficking in cocaine, conspiracy to violate drug laws, and conspiracy to commit money laundering. The charges stemmed from an investigation originating, in part, from evidence acquired during a search of a codefendant's cell phone. The owner of the telephone filed a motion to suppress evidence obtained as a result of the search of his phone, including the contents of text messages sent by Defendant. Defendant moved to join the motion. The Commonwealth opposed the motion, arguing that Defendant lacked standing to challenge the search. The judge ruled that Defendant had standing and allowed him to join the motion. The Supreme Judicial Court reversed, holding that Defendant could not challenge the reasonableness of the search because he lacked a reasonable expectation of privacy in the sent text messages. View "Commonwealth v. Delgado-Rivera" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for two counts of murder in the first degree and the denial of his motion for a new trial, holding that Defendant was not deprived of his constitutional right to the effective assistance of counsel.On appeal, Defendant argued, among other things, that it was manifestly unreasonable for his trial counsel to forgo mental health defenses in favor of a third-party culprit defense. The Supreme Judicial Court disagreed, holding (1) trial counsel was not ineffective for urging one defense over the other, and Defendant was not prejudiced by his trial counsel's performance; and (2) there was no basis upon which to exercise the Court's extraordinary authority to order a new trial or to reduce the verdicts pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Velez" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of both deliberate premeditation and extreme atrocity or cruelty, holding that there was no reversible error either in any issue raised by Defendant or in this Court's review under Mass. Gen. Laws ch. 33E.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress handwritten note and oral statements he made to officers while he was hospitalized; (2) Defendant was not entitled to reversal of his convictions on the grounds of error in the trial judge's evidentiary rulings; (3) the trial judge did not err in denying Defendant's motion for a new trial; and (4) there was no basis for reducing Defendant's sentence on the murder conviction or ordering a new trial. View "Commonwealth v. Welch" on Justia Law

The Supreme Judicial Court affirmed the allowance of Defendant's motion for a new trial, holding that the evidence supporting the charge of armed home invasion was insufficient to allow a finding beyond a reasonable doubt on each element of the offense.Defendant was convicted of armed home invasion, armed burglary, robbery while armed and masked, and other charges. Defendant later filed a motion for a new trial on the charge of armed home invasion, arguing that there was insufficient evidence that he was armed when he entered the building. The superior court allowed the motion. The Supreme Judicial Court affirmed and vacated and set aside Defendant's conviction of armed home invasion, holding that because there was no evidence that Defendant armed himself with a weapon before he entered the building, he could not be convicted of armed home invasion. The Court remanded the matter to the superior court for reconsideration of the sentencing scheme on the remaining convictions. View "Commonwealth v. Tinsley" on Justia Law

The Supreme Judicial Court reversed the order of the trial judge denying Defendant's motion to continue his evidentiary hearing on his motion to suppress until it could be held in person, holding that the trial judge abused her discretion.Defendant, who was charged with a drug offense, filed a motion to suppress evidence and statements. After the suppression hearing was postponed for a third time because of the COVID-19 pandemic the judge ordered that the hearing take place via Zoom. Defendant filed a motion objecting to the Zoom hearing and requested that the case be continued until an in-court hearing could be held safely. The judge denied the motion. The Supreme Judicial Court reversed, holding that because Defendant waived his right to a speedy trial and there were no civilian victims or witnesses, the trial judge abused her discretion in denying Defendant's objection to conducting the evidentiary hearing on his motion to suppress via Zoom video conference. View "Diaz v. Commonwealth" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of extreme atrocity or cruelty, holding that there was no error that would require reversal of Defendant's convictions.Defendant's first trial ended in a mistrial because the jury were unable to reach a verdict. After a retrial, Defendant was convicted of murder. On appeal, Defendant challenged the trial court's denial of his motion to suppress his cell site location information (CSLI) and any "fruits" derived from it. The Supreme Judicial Court affirmed, holding (1) law enforcement infringed upon Defendant's reasonable expectation of privacy in his CSLI without a warrant, but the error was harmless; (2) trial counsel was not ineffective for failing to instruction to certain portions of the jury instructions; and (3) Defendant was not entitled to relief on his remaining claims of error. View "Commonwealth v. Gumkowski" on Justia Law

The Supreme Judicial Court reversed Defendant's conviction of two counts of assault and battery by means of a dangerous weapon resulting in serious injury, holding that the trial court judge erred in excluding one of Defendant's experts, and this error was prejudicial.At trial, Defendant argued that he acted in self-defense and that the two men involved in the altercation were motivated to attack him by racial animus. To support his theory, Defendant sought to introduce the testimony of two experts who would testify that the tattoo found on one of the men was affiliated with a group that espoused white supremacist beliefs. The judge excluded both efforts on reliability grounds. The Supreme Judicial Court reversed and remanded the case for a new trial, holding that the trial judge abused his discretion in excluding the testimony of one of the experts, and this error was prejudicial. View "Commonwealth v. Hinds" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying Petitioner's petition filed pursuant to Mass. Gen. Laws, ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner was charged with trafficking in heroin, operating a motor vehicle with a suspended license, and two civil motor vehicle infractions. Petitioner filed a motion to suppress, which was denied. Petitioner subsequently filed a motion for leave to file a renewed motion to suppress, as well as a motion for recusal of the district court judge. The judge denied both motions. Petitioner then filed his Mass. Gen. Laws ch. 211, 3 petition arguing that the trial judge made multiple decisions that were unfairly prejudicial to him. The single justice denied relief. The Supreme Judicial Court affirmed, holding that there was nothing exceptional about Petitioner's case that warranted the exercise of this Court's extraordinary power. View "Torres v. Commonwealth" on Justia Law