Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendants Kevin McCormack and Brian Porreca of murder in the first degree, holding that there was no reversible error in the proceedings below.Specifically, the Court held (1) there was sufficient evidence to support each defendant’s murder conviction; (2) there trial judge did not err in concluding that there were no Brady violations; (3) there was no “newly discovered” evidence requiring a new trial; (4) Defendants’ rights to confrontation and due process were protected when a DNA expert testified at trial; (5) discovery violations in this case did not implicate the confrontation clause; (6) Defendants’ motion for disclosure of a confidential informant’s identity was properly denied; and (7) there was no reason for the Court to order a new trial or to reduce the degree of guilt under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Barry" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of involuntary manslaughter as a youthful offender, holding that the evidence proved that, by her wanton or reckless misconduct, Defendant caused the victim’s death by suicide and that Defendant’s conviction was not legally or constitutionally infirm.The trial judge concluded that Defendant’s act of encouraging the victim with text messages and phone calls to commit suicide and failure to act to overpowered the victim’s will to live and caused the victim’s death. The Supreme Court affirmed, holding (1) the evidence at trial was sufficient to establish Defendant’s guilt beyond a reasonable doubt; (2) Defendant’s verbal conduct was not protected by the First Amendment; and (3) the other legal issues raise by Defendant lacked merit. View "Commonwealth v. Carter" on Justia Law

The Supreme Judicial Court affirmed the judgment of a municipal court judge civilly committing M.C. for a period of two months, holding that the record contained sufficient evidence to support M.C.’s involuntary commitment and that M.C. was not denied due process of law despite the hearing being conducted at a hospital rather than at a court house and in the absence of a complete, verbatim transcript.Although M.C. sought to have the civil commitment hearing conducted at a court house, the hearing was held at the psychiatric facility where M.C. had been temporarily committed. At the beginning of the proceeding the court-owned recording equipment malfunctioned, and then two different alternate recording devices were used to record the remainder of the hearing. The Supreme Judicial Court affirmed the judge’s decision to civilly commit M.C., holding that the available transcript provided an adequate basis for appellate review and contained sufficient evidence to support M.C.’s involuntary commitment. View "In re M.C." on Justia Law

The Supreme Judicial Court vacated the superior court’s allowance of Defendant’s motion for summary judgment and remanded this discrimination case, holding that the trial judge erred in determining that Plaintiff had failed to meet his burden of showing a prima facie case of discrimination.Plaintiff, a lieutenant in the Massachusetts State police, brought this Mass. Gen. Laws ch. 151B, 4 action alleging that he suffered discrimination when he was denied a transfer to a different troop station on the basis of his age, race, or national origin. The superior court granted summary judgment in favor of the State police, holding that Plaintiff did not meet his burden of showing that the denial of his request for a lateral transfer was an “adverse employment action.” The Supreme Judicial Court vacated the superior court’s judgment, holding (1) under certain circumstances, the failure to grant a lateral transfer to a preferred position may constitute an adverse employment action under ch. 151B; and (2) because Plaintiff met his burden of showing a prima facie case of discrimination, this case is remanded to the motion judge to decide the issue of whether Plaintiff’s request for a lateral transfer was motivated by discriminatory animus. View "Yee v. Massachusetts State Police" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for unlawful possession of drugs found within a locked glove compartment, holding that the trial court did not err in denying Defendant’s motion to suppress and that Defendant was not deprived of the effective assistance of counsel.In denying Defendant’s motion to suppress the motion judge found that the police had probable cause to arrest Defendant for operating a motor vehicle while under the influence of marijuana and that the search of the vehicle was justified as an inventory search. The Supreme Judicial Court affirmed, holding (1) the trial judge was warranted in finding that police had probable cause to believe that Defendant had operated a motor vehicle while impaired; and (2) while the motion judge’s decision to deny the motion to suppress was improper on the grounds that the police conducted a lawful inventory search, the officers had authority to search the vehicle, pursuant to the automobile exception, for evidence pertaining to the offense of operating a motor vehicle while under the influence. View "Commonwealth v. Davis" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree on a theory of deliberate premeditation and declined to grant extraordinary relief under Mass. Gen. Laws ch. 278, 33E, holding that the prosecutor did not commit misconduct during closing argument and that the supplemental instructions provided to the jury in response to a question the jury submitted during deliberations were not in error.On appeal, Defendant argued that the prosecutor’s method of presenting grant jury testimony was flawed and that erroneous jury instructions entitled him to a reversal of his convictions. The Supreme Judicial Court disagreed, holding that the prosecutor’s method of presenting the grand jury testimony was not in error and that the instruction the judge gave in response to the jury’s question was a correct statement of the law. View "Commonwealth v. Andrade" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court judge allowing Defendant’s motion to suppress evidence that was found in plain view during a protective sweep on the basis that the officers’ entry into Defendant’s home was not justified based on exigent circumstances, holding that the judge properly found that the police created the exigency that prompted their warrantless entry into Defendant’s dwelling.Specifically, the Supreme Judicial Court held (1) article 14 of the Massachusetts Declaration of Rights provides greater protection than the Fourteenth Amendment where the police have relied on a reasonably foreseeable exigency to justify the warrantless entry into a dwelling; (2) under the circumstances of this case, the arrest of Defendant in his dwelling without a warrant was unreasonable; and (3) the Commonwealth waived the argument regarding whether, if the permissible observations from the affidavit were redacted, the search warrant was based on probable cause. View "Commonwealth v. Alexis" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions as a joint venturer of kidnapping and murder in the first degree and the denial of his motions for a new trial and for post trial discovery and further declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that Defendant was not entitled to relief.Specifically, the Court held (1) Defendant’s motion to suppress evidence obtained from his clothing was properly denied; (2) statements that the prosecutor made during closing argument regarding blood evidence connecting Defendant to the crime did not create a substantial likelihood of a miscarriage of justice; (3) Defendant did not receive ineffective assistance of counsel; and (4) there was no reason to reduce the degree of guilt or grant a new trial pursuant to the Court’s superintendence powers. View "Commonwealth v. Parker" on Justia Law

The Supreme Judicial Court vacated the district court denial of Defendant’s motion for a new trial after he pleaded guilty to violating multiple controlled substances laws, holding that remand was required for further proceedings on Defendant’s claim of ineffective assistance of counsel because the judge might have failed to recognize his discretion to credit or discredit Defendant’s affidavits as they pertained to plea counsel’s allegedly deficient performance and failed to make factual findings about whether special circumstances relevant to the prejudice inquiry existed.After Defendant entered his plea, he filed a motion for a new trial pursuant to Mass. R. Crim. P. 30(b), arguing that his counsel had rendered ineffective assistance and that he would not have pleaded guilty if counsel had properly advised him about the plea’s immigration consequences. The motion judge denied the motion after holding a nonevidentiary hearing. The Supreme Judicial Court vacated the denial of the motion for a new trial, holding that remand was required for findings relating to the issue of plea counsel’s deficient performance and the issue of special circumstances. View "Commonwealth v. Lys" on Justia Law

The Supreme Judicial Court affirmed the order of the motion judge allowing Defendant’s motion to suppress evidence discovered when police officers “froze” a house while they obtained a warrant, holding that the suppression order was proper because there was an insufficient basis to believe that evidence would be lost or destroyed.The court of appeals reversed the suppression order, concluding that the police officers’ actions were justified to prevent the removal or destruction of evidence. The Supreme Judicial Court disagreed, holding that that police officers were not justified in conducting a warrantless search to prevent the loss or destruction of evidence. View "Commonwealth v. Owens" on Justia Law