Justia Massachusetts Supreme Court Opinion Summaries
Articles Posted in Civil Rights
Commonwealth v. Armstrong
The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty and sentence of life without parole, holding that Defendant was not entitled to relief on his allegations of error and that there was no reason to grant relief under Mass. Gen. Laws ch. 278, 33E.Specifically, the Supreme Judicial Court held (1) the motion judge did not err in denying Defendant's motion to suppress evidence from the police officers who arrested him; (2) the trial judge did not err in denying Defendant's request for a mental impairment jury instruction; (3) testimony by the Commonwealth's fingerprint analysis expert was not improper; and (4) this Court discerns no reason to grant relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Armstrong" on Justia Law
Commonwealth v. Miranda
The Supreme Judicial Court vacated Defendant's conviction of murder in the first degree and remanded this case for further proceedings, holding that the trial justice erred when he failed to instruct the jury on the impact of mental impairment and intoxication on whether Defendant acted in a cruel or atrocious manner, and this error created a substantial likelihood of a miscarriage of justice.Following a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty for the death of a woman who died from multiple chop wounds from a machete. On appeal from the denial of his motion for a new trial, Defendant argued that the trial justice erred by failing to provide two jury instructions regarding mitigating circumstances. The Supreme Judicial Court vacated Defendant's conviction, holding that the trial justice did not err by omitting Defendant's requested instructions on sudden combat but did err in failing to give an instruction on mental impairment as it related to extreme atrocity or cruelty, and the error created a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Miranda" on Justia Law
Adams v. Schneider Electric USA
The Supreme Judicial Court reversed the decision of the superior court granting summary judgment in favor of Defendant in this age discrimination action, holding that Plaintiff produced sufficient evidence to create a dispute of fact regarding whether he was terminated due to discriminatory animus.Plaintiff sued Defendant, his former employer, after he was laid off in a reduction in force. The superior court granted summary judgment in favor of Defendant, determining that Plaintiff could not show that Defendant's stated justification for his termination was pretextual. The appeals court reversed. The Supreme Judicial Court remanded the case to the superior court for further proceedings, holding that Plaintiff produced evidence from which a jury could find that he was selected for the reduction in force as part of a corporate strategy to lay off older workers. View "Adams v. Schneider Electric USA" on Justia Law
Posted in:
Civil Rights, Labor & Employment Law
Commonwealth v. Dew
The Supreme Judicial Court vacated Defendant's convictions for five counts of trafficking a person for sexual servitude and a second and subsequent offense of possession of a class A substance with intent to distribute, holding that the conflict of interest inherent in counsel's bigotry against persons of Defendant's faith and race deprived Defendant of his right to effective assistance of counsel.Defendant, a Black man of the Muslim faith, was appointed counsel who openly shared his hatred of and bigotry against people of the Muslim faith and his racism against Black persons. Counsel advised Defendant to accept a plea deal, which Defendant did. Defendant later filed a motion to withdraw his guilty plea and for a new trial, arguing that his counsel had an actual conflict of interest. The motion judge denied the motion. The Supreme Judicial Court reversed and remanded the case for a new trial, holding that Defendant met his burden to establish that counsel's representation of him was impaired by an actual conflict of interest. View "Commonwealth v. Dew" on Justia Law
Commonwealth v. Delossantos
The Supreme Judicial Court vacated Defendant's conviction of carrying a firearm without a license and his sentence of eighteen months in a house of correction, holding that the Commonwealth did not demonstrate beyond a reasonable doubt that Defendant knowingly, intelligently, and voluntarily waived his Miranda rights, and Defendant did not waive this issue.In a pretrial motion, Defendant filed a motion to suppress based on the alleged inadequacy of the Miranda warnings provided to him in Spanish. The motion judge denied the motion after finding that Defendant was given "the full complement of Miranda warnings" in English and in Spanish. After he was convicted and the convictions were affirmed on appeal Defendant filed a postconviction motion for a new trial, which the motion judge denied following a hearing. The appeals court affirmed. The Supreme Judicial Court vacated the conviction, holding (1) Defendant did not waive the issue of whether Miranda warnings were properly given to him in Spanish; and (2) the admission of Defendant's post arrest statements was error. View "Commonwealth v. Delossantos" on Justia Law
Commonwealth v. Wittey
The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of both deliberate premeditation and extreme atrocity or cruelty, holding that there was no error in the underlying proceedings or in the verdict.On appeal, Defendant argued, among other things, that the district court erred in denying his motion to suppress the evidence recovered pursuant to a search warrant following a police trooper's examination of Defendant's vehicle, which was visibly parked in the driveway leading up to his house. The Supreme Judicial Court affirmed, holding (1) because Defendant's vehicle was not parked within the curtilage of his home the trooper's observations of the vehicle did not constitute a search for constitutional purposes; and (2) there was no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial. View "Commonwealth v. Wittey" on Justia Law
Commonwealth v. Samia
The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of deliberate premeditation but vacated his conviction of murder in the first degree on a theory of felony-murder, holding that the felony-murder conviction was improper.Defendant was convicted of murder in the first degree on theories of deliberate premeditation and felony-murder, with aggravated kidnapping as the predicate felony. In this appeal, consolidated with the appeal of his motions for a new trial and for reconsideration, Defendant argued, and the Commonwealth conceded, that the conviction of murder in the first degree on a theory of felony-murder was improper because the predicate felony of aggravated kidnapping did not exist at the time of the killing. The Supreme Court vacated Defendant's felony-murder conviction and otherwise affirmed, holding (1) Defendant's conviction of felony-murder lacked sufficient evidence to support it; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Samia" on Justia Law
Commonwealth v. Monteiro
The Supreme Judicial Court affirmed the judgment of the county court denying the Commonwealth's petition filed under Mass. Gen. Laws ch. 211, 3 seeking relief from a superior court judge's denial of the Commonwealth's motion to disqualify Rosemary Scapicchio, Defendant's appellate counsel, on the ground that she had a conflict of interest, holding that the single justice did not err or abuse his discretion in denying the motion.Defendant was convicted of murder in the first degree. Later, represented by Scapicchio, Defendant filed a motion for a new trial alleging ineffective of counsel. Thereafter, Scapicchio represented Michael Barros at a hearing in an unrelated criminal case. The Commonwealth moved to disqualify Scapicchio on the grounds that her representation of both Defendant and Barros gave rise to a conflict of interest. The superior court denied the motion. The Commonwealth then filed the petition at issue. The single justice denied relief without reaching its merits. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused his discretion by denying the petition. View "Commonwealth v. Monteiro" on Justia Law
Kifor v. Commonwealth
The Supreme Judicial Court affirmed the judgment of the county court denying, without a hearing, Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion by denying relief.Petitioner alleged in his petition that a number of State actors had been engaged in "deliberately child-predatory and subversionary public nuisance activities" in furtherance of a conspiracy against him. The single justice denied relief. The Supreme Judicial Court affirmed and took measures intended to prevent Petitioner from further abusing the system, holding that the single justice was not obligated to exercise the court's superintendent power to become involved in this matter. View "Kifor v. Commonwealth" on Justia Law
Posted in:
Civil Rights
Herrmann v. Attorney General
The Supreme Judicial Court declined to address the merits of these appeals challenging the Attorney General's (AG) decision denying Plaintiffs' initiative petition that would have instituted limits on contributions to independent expenditure political action committees, holding that the appeals were moot.The AG determined that the proposed law conflicted with the Massachusetts Declaration of Rights' right of free speech and, therefore, addressed an excluded subject under article 48. Ultimately, the AG concluded that the proposed limitation on campaign contributions was precluded under United States Supreme Court precedent. Plaintiffs appealed. Thereafter, the AG offered to agree to a stipulated order, but Plaintiffs refused to agree with the order. Before the Supreme Judicial Court, the AG argued that the appeals were moot because Plaintiffs did not gather the first round of signatures set forth in article 48. The Supreme Judicial Court dismissed the cases as moot, holding that Plaintiffs failed to meet the deadline to file additional signatures with the Secretary of the Commonwealth. View "Herrmann v. Attorney General" on Justia Law