Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court held that, by failing to raise a timely objection to an improper courtroom closure at trial, a defendant forfeits or procedurally waives his or her entitlement to the standard of review designated for meritorious and preserved claims of structural error, even if counsel and Defendant were subjectively unaware that the courtroom had been closed at trial.The motion judge granted Defendant’s motion for a new trial, concluding that because Defendant and his counsel were unaware that the courtroom had been closing during empanelment, counsel’s failure to contemporaneously object to the close did not constitute a procedural waiver of his claim that he was denied his Sixth Amendment right to a public trial. The Supreme Judicial Court reversed, holding (1) Defendant’s claim was procedurally waived despite the fact that he and his counsel were factually unaware of the courtroom closure when it occurred at trial; and (2) where a procedurally-waived Sixth Amendment public trial claim is raised in a motion for a new trial, a reviewing court analyzes the purported error to determine whether the error created a substantial risk of a miscarriage of justice. The court remanded the case for review of Defendant’s claim under the appropriate standard. View "Commonwealth v. Robinson" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree on the theory of extreme atrocity or cruelty and other crimes, holding that, although certain of the prosecutor’s questions and comments concerning Defendant’s prearrest silence were improper, these errors did not create a substantial likelihood of a miscarriage of justice.The Court further held (1) there was ample evidence to support the prosecutor’s statement during closing argument that Defendant struck the victim repeatedly with a hammer; and (2) there was no error in the judge’s instructions on the lesser included offenses to murder in the first degree. View "Commonwealth v. Gardner" on Justia Law

The Supreme Judicial Court reversed the superior court judge decision allowing Defendants’ motion to suppress statements made to detectives and pills found in one of the defendant’s vehicles on the grounds that Defendants had been subject to custodial interrogation without, in one case, any Miranda warnings and, in the other case, an inadequate warning.Defendants were two individuals who had been detained in a restaurant parking lot as part of a threshold inquiry into a street-level drug transaction. The grand jury indicted Defendants of drug offenses. The superior court allowed Defendants’ motions to suppress. The Supreme Judicial Court reversed, holding that, applying the factors set out in Commonwealth v. Groome, 435 Mass. 201, 211-212 (2001), to the circumstances of this case, Defendants did not meet their burden of showing that they were in custody when they made the incriminating statements. View "Commonwealth v. Cawthron" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree and other offenses, affirmed the trial judge’s order denying Defendant’s motion for a new trial, and declined to reduce or set aside Defendant’s convictions under Mass. Gen. Laws ch. 278, 33E.During trial, the defense attorney failed to adhere to the judge’s courtroom rules, made inappropriate comments in the presence of the jury, and interrupted the judge on multiple occasions. The Supreme Judicial Court held (1) the judge’s admonishments to defense counsel were well within the judge’s authority, and the judge’s jury instructions mitigated any potential prejudice that might have resulted from the jury observing the disputes; (2) the reconstruction of a missing portion of the record was proper and adequate; (3) there was no evidentiary error; and (4) any purported error in the Commonwealth’s closing statement was not prejudicial. Further, the Court declined to exercise its section 33E power based on friction generated as a result of the judge having to rein in defense counsel’s inappropriate courtroom conduct. View "Commonwealth v. Imbert" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree and other offenses, affirmed the trial judge’s order denying Defendant’s motion for a new trial, and declined to reduce or set aside Defendant’s convictions under Mass. Gen. Laws ch. 278, 33E.During trial, the defense attorney failed to adhere to the judge’s courtroom rules, made inappropriate comments in the presence of the jury, and interrupted the judge on multiple occasions. The Supreme Judicial Court held (1) the judge’s admonishments to defense counsel were well within the judge’s authority, and the judge’s jury instructions mitigated any potential prejudice that might have resulted from the jury observing the disputes; (2) the reconstruction of a missing portion of the record was proper and adequate; (3) there was no evidentiary error; and (4) any purported error in the Commonwealth’s closing statement was not prejudicial. Further, the Court declined to exercise its section 33E power based on friction generated as a result of the judge having to rein in defense counsel’s inappropriate courtroom conduct. View "Commonwealth v. Imbert" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree, holding that the seating of a certain juror did not violate Defendant's right to a fair and impartial jury.On appeal, Defendant argued that the seating of an alleged biased juror violated his right to a fair and impartial jury under the Sixth Amendment to the United States Constitution and article 12 of the Massachusetts Declaration of Rights. The Supreme Judicial Court disagreed, holding (1) the trial judge conducted a sufficient colloquy with the juror to determine that he would not be a biased juror; and (2) the defense that the Commonwealth did not meet its burden of proof was without merit, and this Court declines to reduce the degree of guilt or order a new trial under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Lee" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree on a theory of felony-murder and armed robbery and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E. The Court held (1) the trial judge violated Defendant’s right to confront witnesses by allowing the jury to be exposed to certain hearsay, but the error was harmless beyond a reasonable doubt; (2) the trial judge erred by allowing a substitute expert witnesses to testify to a match between the defendant's DNA profile and one obtained from the victim's clothing, but the error did not result in a substantial likelihood of a miscarriage of justice; (3) Defendant’s trial counsel was not ineffective; and (4) government officials did not commit unconstitutional misconduct in the course of investigating and prosecuting Defendant. View "Commonwealth v. Seino" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree on a theory of felony-murder and armed robbery and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E. The Court held (1) the trial judge violated Defendant’s right to confront witnesses by allowing the jury to be exposed to certain hearsay, but the error was harmless beyond a reasonable doubt; (2) the trial judge erred by allowing a substitute expert witnesses to testify to a match between the defendant's DNA profile and one obtained from the victim's clothing, but the error did not result in a substantial likelihood of a miscarriage of justice; (3) Defendant’s trial counsel was not ineffective; and (4) government officials did not commit unconstitutional misconduct in the course of investigating and prosecuting Defendant. View "Commonwealth v. Seino" on Justia Law

Plaintiffs, five students who attend public schools in the city of Boston, failed to state a claim for relief in their complaint alleging that the charter school cap under Mass. Gen. Laws ch. 71, 89(i) violates the education clause and the equal protection provisions of the Massachusetts Constitution because Plaintiffs were not able to attend public charter schools of their choosing.Plaintiffs sued the Secretary of Education, the chair and members of the board of secondary and elementary education, and the Commissioner of Education seeking declaratory and injunctive relief. Defendants filed a motion to dismiss. The motion judge granted the motion, concluding that Plaintiffs failed to state a claim under either the education clause or the equal protection provisions of the Massachusetts Declaration of Rights. The Supreme Judicial Court affirmed, holding (1) Plaintiffs failed to allege facts suggesting not only that they had been deprived of an adequate education but that Defendants failed to fulfill their constitutionally prescribed duty to educate; and (2) there was no plausible set of facts that Plaintiffs could prove to support a conclusion that the charter school cap did not have a rational basis. View "Doe No. 1 v. Secretary of Education" on Justia Law

The absolute prohibition against civilian possession of stun guns under Mass. Gen. Laws ch. 140, 131J violates the Second Amendment to the United States Constitution.Defendant was charged with possession of a stun gun, among other crimes. Defendant to dismissed that count of the complaint, arguing that section 131J’s criminal prohibition of the possession of stun guns by civilians violates the Second Amendment. The trial judge denied the motion. The Supreme Judicial Court vacated the district court’s order denying Defendant’s motion to dismiss and directed the judge to allow the motion, holding (1) stun guns are “arms” within the protection of the Second Amendment and therefore may be regulated but not absolutely banned; (2) consequently, the absolute prohibition in section 131J that bars all civilians from possessing or carrying stun guns, even in their home, violates the Second Amendment; and (3) section 131J in its current form is facially invalid. View "Ramirez v. Commonwealth" on Justia Law