Justia Massachusetts Supreme Court Opinion Summaries

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

The Supreme Judicial Court held in this case that the principles of double jeopardy bar the imposition of a consecutive sentence of eight years’ probation, imposed in 2015 by a judge who was not the plea judge, where Defendant originally had been sentenced in 2005 to an eight-year term of probation concurrent with his ten-year prison sentence. Specifically, Defendant was not resentenced to a term of consecutive probation when the original sentencing judge vacated the community parole supervision for life portion of his sentence. The court remanded the matter to the superior court for entry of an order dismissing the Commonwealth’s motion to correct and clarify the sentence as moot on the ground that Defendant’s sentence had been completed before the motion was filed. View "Commonwealth v. Pacheco" on Justia Law

Plaintiff and Defendants owned abutting parcels of property. After several years of Defendants opposing Plaintiff’s redevelopment plans, Plaintiff filed a complaint alleging abuse of process and a violation of Mass. Gen. Laws ch. 93A, 11. Defendants filed a special motion to dismiss pursuant to the “anti-SLAPP statute,” Mass. Gen. Laws ch. 231, 59H. A superior court judge denied the motion. The Supreme Judicial Court (1) affirmed the denial of Defendants’ special motion to dismiss with respect to Plaintiff’s claim under Mass. Gen. Laws ch. 93A, 11; and (2) vacated the denial of the special motion to dismiss with respect to Plaintiff’s abuse of process claim, holding that Defendants met their threshold burden under the anti-SLAPP statute of showing that this claim was solely based on Defendants’ petitioning activity. Given that Plaintiff has not demonstrated that the entirety of Defendants’ petitioning activities lack a reasonable basis in fact or law, it may attempt upon remand to make the showing outlined in Blanchard v. Steward Carney Hospital, Inc., 477 Mass. , (2017), which augments the framework in Duracraft Corp. v. Holmes Products Corp., 427 Mass. 156 (1998). View "477 Harrison Ave., LLC v. JACE Boston, LLC" on Justia Law

The Supreme Judicial Court took this opportunity to augment the framework set forth in Duracraft v. Holmes Products Corp., 427 Mass. 156 (1998), regarding anti-SLAPP suits. Plaintiffs, nine registered nurses who previously worked in a hospital's adolescent psychiatric unit, fired the hospital and its then-president, alleging defamation based on the president’s statements - both to hospital employees and to the Boston Globe - regarding the nurses’ culpability for the incidents that took place at the unit. Defendants filed a special motion to dismiss pursuant to the “anti-SLAPP statute,” Mass. Gen. Laws ch. 231, 59H. The superior court denied the motion. The Supreme Judicial Court vacated the denial of Defendants’ special motion to dismiss as to the president’s statements to the Boston Globe and otherwise affirmed, holding that a portion of Plaintiffs’ defamation claim was based solely on Defendants’ petitioning activity. Therefore, Defendants satisfied in part their threshold burden under Duracraft. However, because the statute, as construed under current case law, remains at odds with legislative intent and raises constitutional concerns, the court broadened the construction of the statutory term “based on.” The court remanded the matter to the superior court where the burden will shift to Plaintiffs to make a showing adequate to defeat the special motion to dismiss. View "Blanchard v. Steward Carney Hospital, Inc." on Justia Law