Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the superior court’s denial of Defendant’s motion for a new trial. Following a jury-waived trial, Defendant was convicted of rape, subsequent offense, and indecent assault and battery on a person age fourteen or older. In his motion for a new trial, Defendant argued that his jury waiver was neither knowing nor negligent and that defense counsel was constitutionally ineffective because neither the trial judge nor counsel disclosed that the judge’s son was employed as an assistant district attorney in the office of the district attorney for the district that prosecuted the indictments. The Supreme Judicial held (1) the trial judge’s failure to inform Defendant of his familial relationship with a member of the prosecuting attorney’s office during the jury-waiver colloquy was not error; and (2) although counsel’s failure to inform Defendant of the judge’s familial relationship with a member of the prosecuting attorney’s office fell below behavior that might be expected from an ordinary lawyer, counsel’s failure to do so was not prejudicial. View "Commonwealth v. Duart" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree on the theories of extreme atrocity or cruelty and felony murder with home invasion and armed burglary, assault on occupant as the predicate felonies, and declined to grant relief under Mass. Gen. Laws ch. 278, 33E. The court held (1) there was no error in the trial court’s denial of Defendant’s motion to suppress statements he made during an interview with the police; (2) there was no prejudicial error in the admission of hearsay testimony from various witnesses; (3) the trial judge erred in denying Defendant’s request for a DiGiambattista instruction where a portion of Defendant’s interview with the police was not audio recored, but the error was not prejudicial; (4) the trial court did not err in denying Defendant’s motion for a mistrial following the jury’s exposure to inadmissible evidence; and (5) a statement made in the prosecutor’s closing argument was impermissible, but no substantial likelihood of a miscarriage of justice arose from the statement. View "Commonwealth v. Santana" on Justia Law

The Supreme Judicial Court vacated Defendant’s convictions for carrying firearm without a license and receiving stolen property valued over $250. The convictions arose from a search of Defendant’s backpack after he was arrested for possession of a controlled substance and breaking and entering a residence. On appeal, Defendant argued that the trial judge erred in denying his motion to suppress images discovered as the result of the warrantless search of a digital camera discovered in his backpack and that the evidence was insufficient to sustain his conviction of receiving stolen property valued over $250. The Supreme Judicial Court held (1) the warrantless search of the digital camera was neither a valid search incident to arrest nor a valid inventory search, and therefore, the trial judge erred in denying Defendant’s motion to suppress; and (2) the evidence was insufficient to sustain Defendant’s remaining conviction, but a conviction of the lesser included offense must stand. View "Commonwealth v. Mauricio" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction, rendered after a jury verdict, of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. On appeal, Defendant asserted several claims of ineffective assistance of counsel and challenged the denial of her motion for a new trial based on ineffective assistance. The court held (1) although trial counsel erred by failing to consult with a mental health expert, the error did not require reversal of Defendant’s conviction; and (2) the interests of justice did not require entry of a lesser degree of guilt. View "Commonwealth v. Field" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for raping a fourteen-year-old boy and two thirteen-year-old boys. The court held (1) the trial judge did not err in denying Defendant’s motion to suppress incriminating statements she made to the police because, based on the totality of the circumstances, Defendant’s confession was voluntary; (2) the trial court’s decision not to further redact the video recording of Defendant’s incriminating statements that was shown at trial was within the range of reasonable alternatives; (3) although two of the prosecutor’s closing statements during closing argument were improper, the statements were not prejudicial; and (4) the trial judge’s lack of authority to relieve Defendant from registering as a sex offender under Mass. Gen. Laws ch. 6, 178E(f) did not constitute a due process violation as applied to Defendant. View "Commonwealth v. Hammond" on Justia Law

A patient who qualifies for the medical use of marijuana and has been terminated from her employment because she tested positive for marijuana as a result of her lawful medical use of marijuana may seek a civil remedy against her employer through claims of handicap discrimination in violation of Mass. Gen. Laws ch. 151B. The Supreme Judicial Court thus reversed the dismissal of Plaintiff’s claim for handicap discrimination and related claims under chapter 151B but affirmed the allowance of the motion to dismiss as to the counts claiming an implied private cause of action under the medical marijuana act and wrongful termination in violation of public policy, holding that there is no implied statutory private cause of action under the medical marijuana act and that Plaintiff failed to state a claim for wrongful termination in violation of public policy. View "Barbuto v. Advantage Sales & Marketing, LLC" on Justia Law

Double jeopardy principles did not preclude the Commonwealth from retrying Defendant on a complaint charging a violation of Mass. Gen. Laws ch. 90, 24(1)(a)(1) on the theory of operation of a motor vehicle with a percentage of alcohol in his blood of .08 or greater (per se violation) after a jury acquitted Defendant on the theory of operation of a motor vehicle while under the influence of intoxicating liquor (impaired ability violation). The Commonwealth prosecuted the case on both theories, and the jury reached a verdict on the impaired ability violation only. After a new complaint issued charging a per se violation of chapter 90, section 24(1)(a)(1), Defendant moved to dismiss the complaint as a violation of his double jeopardy rights.The judge denied the motion. The Supreme court affirmed, holding that retrial was constitutionally permitted where the Commonwealth prosecuted the case on both theories and the jury reached a verdict on only one of those theories. View "Commonwealth v. Hebb" on Justia Law

The Supreme Judicial Court reversed the denial of Defendant’s motion to suppress evidence recovered pursuant to a search warrant, holding that the search warrant lacked probable cause.Defendant was indicted on various charges in connection with the possession of an unlicensed firearm. Two of those charges included sentence enhancement as an armed career criminal. Defendant filed a motion to suppress evidence recovered from a safe pursuant to a search warrant and also moved to dismiss the sentence enhancements. Both motions were denied. The Supreme Judicial Court reversed the denial of both motions and remanded the matters to the county court, holding (1) the search warrant that yielded a gun, a magazine, and ammunition lacked probable cause; and (2) the Commonwealth failed to present sufficient evidence to the grand jury to support the armed career criminal enhancements. View "Commonwealth v. Mora" on Justia Law

The Supreme Judicial Court vacated Defendant’s conviction of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. The court held (1) while not overwhelming, the evidence presented at trial was sufficient as a matter of law to support Defendant’s conviction of murder in the first degree, and therefore, there was no error in the judge’s denial of Defendant’s motion for a required finding; but (2) the trial judge’s failure to require an explanation of the prosecutor’s peremptory challenge of a prospective juror, who was African-American, was error, and because the error constituted structural error for which prejudice is presumed, the case must be remanded to the superior court for a new trial. View "Commonwealth v. Jones" on Justia Law

Once a police officer has completed the investigation of a defendant’s civil traffic violations and the facts do not give rise to reasonable suspicion of criminal activity, the officer is required to permit the defendant to drive away.Defendant filed a motion to suppress evidence seized from the trunk of his vehicle, arguing that state police troopers and local police officers unreasonably detained him beyond the time required to effectuate a traffic stop. A superior court denied the motion to suppress. The Supreme Judicial Court reversed, holding that because the officer’s investigation of civil traffic violations did not give rise to reasonable suspicion of criminal activity, the officer did not have a legitimate basis to justify his investigation of criminal drug activity, and Defendant should have been allowed to drive away. View "Commonwealth v. Cordero" on Justia Law