Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court vacated Defendant's convictions for operating a motor vehicle while under the influence of alcohol (OUI) causing serious bodily injury and misleading an investigator, holding that errors at trial required that Defendant's convictions be vacated and the matter remanded for a retrial.Specifically, the Supreme Judicial Court held (1) the plain language of the relevant statutes makes clear that blood alcohol level testing shall not be done absent consent, and any nonconsensual testing done at the police's direction is inadmissible; (2) because Defendant's blood draw was performed without Defendant's actual consent, the blood draw was impermissible and the blood alcohol content test results were improperly admitted at trial, and the tainted evidence was not harmless beyond a reasonable doubt; and (3) the trial judge erred by failing to make an independent determination regarding the voluntariness of Defendant's statements and by failing to give a humane practice instruction to the jury, and the error created a substantial risk of a miscarriage of justice. View "Commonwealth v. Bohigian" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, holding that there was no reversible error in the proceedings below nor reason to exercise the Court's authority under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) the Commonwealth did not violate Defendant's due process rights by omitting evidence that helped Defendant and that countered the prosecutor's theory of the case; (2) error occurred when a lay witness testified that he had previously referred to Defendant as the "guy...who killed my cousin" but the inadmissible evidence did not create a substantial likelihood of a miscarriage of justice; (3) the prosecutor improperly urged the jury to draw an inference of guilt against Defendant due to his courtroom behavior, but the error did not create a substantial likelihood of a miscarriage of justice; (4) there was no error in the jury instructions regarding circumstantial evidence; (5) Defendant's trial counsel did not provide ineffective assistance; and (6) the motion judges did not err in denying the defendant's motions for posttrial discovery. View "Commonwealth v. Moffat" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of deliberate premeditation and an attempt to suborn perjury and declined to exercise its extraordinary authority under Mass. Gen. Laws ch. 278, 33 E to order a new trial or to reduce the degree of guilt, holding that no prejudicial error occurred in the proceedings below.Specifically, the Supreme Judicial Court held (1) the evidence was sufficient to support Defendant's conviction; (2) the trial court did not err in denying Defendant's motion to suppress cell site location data and admitting that data at trial; (3) the trial judge did not abuse his discretion in allowing into evidence out-of-court statements by Defendant's alleged coventurer and in excluding other evidence concerning that coventurer; (4) the trial judge did not abuse his discretion by allowing the charges against Defendant to be joined for trial; (5) the trial judge did not commit prejudicial error by not giving "missing witness" and Bowden instructions; and (6) improprieties in the prosecutor's closing argument did not create a substantial likelihood of a miscarriage of justice. In addition, the Supreme Judicial Court discerned no reason to order a new trial or to reduce the degree of guilt under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Wilkerson" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree by deliberate premeditation and assault with intent to murder, holding that no error occurred in the proceedings below.Specifically, the Supreme Judicial Court held (1) the motion judge did not err in denying Defendant's motion to suppress because (a) although Defendant unambiguously invoked his right to counsel, he voluntarily reinitiated contact with detectives, and (b) Defendant's waiver of his Miranda rights was intelligent, knowing, and voluntary; (2) factually inconsistent verdicts were no grounds to set aside Defendant's convictions of murder in the first degree and assault with the intent to murder because ample evidence supported both convictions; and (3) the verdict of murder in the first degree was consonant with justice, and there was no basis to set aside the verdict or order a new trial pursuant to the Court's extraordinary power under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Miller" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree and unlawful possession of a firearm, holding that no error occurred during the proceedings below.Specifically, the Supreme Judicial Court held (1) one of the Commonwealth's key witnesses did not provide improper lay testimony on the ultimate issue of Defendant's guilt; (2) Defendant's argument that a substantial likelihood of a miscarriage of justice occurred because the judge did not provide a self-defense instruction sua sponte was without merit; (3) trial counsel did not provide ineffective assistance for strategically deciding against requesting a self-defense instruction; and (4) there was no basis to set aside the verdict of murder in the first degree or to order a new trial pursuant to the Court's extraordinary power under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Waller" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of deliberate premeditation, holding that there was no prejudicial error in the proceedings below.After Defendant was convicted of murder, the Supreme Judicial Court reversed the conviction due to an error in the jury instructions. Following a retrial, Defendant was again convicted of murder. Defendant filed a motion for a new trial, which the trial court denied. The Supreme Judicial Court affirmed, holding (1) the trial judge's decision to allow a witness to avoid testifying at the second trial by invoking the privilege against self-incrimination and in admitting the witness's voir dire testimony, in lieu of live testimony at the second trial, did not create a substantial likelihood of a miscarriage of justice; (2) the trial court did not err in denying Defendant's motion for a new trial on the ground that he suffered from a mental disease or defect at the time of the shooting; (3) this Court again declines to extend its holding in Diatchenko v. District Attorney for the Suffolk District, 466 Mass. 655 (2013), to individuals over the age of eighteen; and (4) Defendant's arguments made pursuant to Commonwealth v. Moffett, 383 Mass. 201, 208-209 (1981) were unavailing. View "Commonwealth v. Johnson" on Justia Law

The Supreme Judicial Court vacated Defendant's guilty plea to a sentencing enhancement and his conviction of unlawful possession of a loaded firearm, holding that where a defendant makes a good faith claim that a deliberating juror reported that racial bias infected the jury's deliberations, a judge may not condition acceptance of a guilty plea to a sentencing enhancement upon a waiver of that claim.Immediately after entry of the guilty verdict in this case, a deliberating juror reported that racial bias influenced the jury's deliberations. Defendant filed a motion to investigate the juror's claims prior to the jury-waived trial on two sentencing enhancements. The prosecutor agreed to nol pros one sentencing enhancement in return for Defendant's guilty plea to the other sentencing enhancement if Defendant withdrew the motion. Defendant withdrew the motion and pleaded guilty to one of the sentencing enhancements. Defendant later moved, unsuccessfully, for a new trial, seeking to vacate his guilty plea to the sentencing enhancement. The Supreme Court ordered a new trial as to the sentencing enhancements, holding that once a defendant's right to a jury trial is invoked a defendant may not waive his right to a verdict that is untainted by racial or ethnic bias. View "Commonwealth v. McCalop" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court granting summary judgment on several claims against police officers personally, holding that there was a genuine issue of material fact whether the police officers used excessive force against Appellant after he was removed from his vehicle.Plaintiff, a black man, was stopped by two police officers. The stop escalated into a physical altercation during which five police officers forcibly removed Plaintiff from the vehicle and wrestled him to the ground. Plaintiff was convicted of several offenses stemming from the incident. While the criminal case was pending, Plaintiff filed a civil action alleging that the officers committed several torts and violated his civil rights. The trial court granted summary judgment for Defendants on the civil action. The Supreme Judicial Court vacated the judgment in part, holding (1) Plaintiff's civil action may only proceed where it is based on facts beyond those that were necessary to sustain Plaintiff's prior criminal conviction and where Plaintiff demonstrates that his claims would not necessarily challenge the validity of his prior criminal conviction; and (2) this conclusion does not bar the claims that Plaintiff based on events that occurred after the police officers forcibly removed him from his vehicle. View "Tinsley v. Town of Framingham" on Justia Law

The Supreme Judicial Court established a revised test for a court to determine whether a defendant seeking to suppress evidence based on a claim that a traffic stop violated equal protection principles.The Supreme Judicial Court reversed the judgment of the district court denying Defendant's motion to suppress the evidence seized from the vehicle he was driving, holding that the trial judge abused his discretion in denying the motion to suppress because Defendant produced sufficient evidence to raise a reasonable inference that the stop was racially motivated. In so holding, the Court concluded (1) a defendant seeking to suppress evidence evidence based on a violation of his or her equal protection rights must establish a reasonable inference that the officer's decision to initiate the stop was motivated by race or another protected class; and (2) to raise this inference, the defendant must point out specific facts from the totality of the circumstances surrounding the stop. View "Commonwealth v. Long" on Justia Law

The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence obtained as a result of a stop, holding that, going forward, the age of a juvenile suspect, if objectively apparent to a reasonable officer, will be part of the totality of the circumstances relevant to whether the juvenile as seized under article 14 of the Massachusetts Declaration of Rights.Minutes after a shooting, two police officers encountered seventeen-year-old Defendant walking on the sidewalk. After attempting to speak with Defendant, one of the officers started to get out of the cruiser, after which Defendant ran. Defendant was charged with murder in the first degree. Defendant filed a motion to suppress. The trial court denied the motion. The Supreme Judicial Court affirmed, holding (1) the trial judge did not abuse his discretion in concluding that the officers had a reasonable, articulable suspicion of criminal activity; (2) a child's age, when known to the officer or objectively apparent to a reasonable officer, is relevant to the question of seizure under article 14; and (3) there was insufficient evidence that the officers knew or should have known prior to his arrest, that Defendant was below the age of eighteen. View "Commonwealth v. Evelyn" on Justia Law