Justia Massachusetts Supreme Court Opinion Summaries

Defendants, Jason Estabrook and Adam Bradley, were indicted for murder and related crimes. At issue in this case was the superior court’s denial of Defendants’ motion to suppress historical cellular site location information (CSLI) pertaining to Bradley’s cellular telephone that police officers obtained without a search warrant and then later reobtained pursuant to a warrant. The judge also refused to suppress statements Defendants made to police following the receipt of Bradley’s CSLI. The Supreme Judicial Court affirmed, holding (1) the Commonwealth does not violate a defendant’s reasonable expectation of privacy when it requests up to six hours of historical CSLI without obtaining a search warrant; (2) because the Commonwealth requested two weeks of historical CSLI in this case, a search warrant was required; but (3) many of Defendants’ statements and Bradley’s CSLI were not subject to suppression due to the CSLI that was first obtained unlawfully because (i) Defendants’ statements were not made in response to being confronted by the tainted CSLI, and (ii) the search warrant was supported by probable cause derived from information obtained independently rather than through the tainted CSLI. View "Commonwealth v. Estabrook" on Justia Law

A police officer stopped a vehicle based on the officer’s detection of an odor of burnt marijuana coming from the vehicle. During the course of the stop, police discovered sixty Percocet pills. Defendant, a passenger in the vehicle at the time of the stop, was charged with several drug-related offenses all in connection with the pills. Defendant moved to suppress evidence of the pills. The motion judge denied the motion to suppress, concluding that the stop was justified. The Supreme Judicial Court reversed, holding that there was at best reasonable suspicion to believe that a civil marijuana infraction was occurring, but not probable cause, and therefore, the stop was impermissible. View "Commonwealth v. Rodriguez" on Justia Law

After a jury trial, Defendant was convicted of rape and furnishing alcohol to a minor. The Supreme Judicial Court vacated Defendant’s convictions and remanded for a new trial, holding (1) the trial judge erred in permitting an expert witness who was not present when the victim’s “rape kit” examination was performed to testify about how the various swabs she tested had been collected, and the error was prejudicial; and (2) the trial judge erred in closing the rape shield hearing to determine the admissibility of evidence relating to the victim’s prior sexual contact with the individual to whom the victim first reported the alleged rape without conducting the four-prong framework required for court room closures under the United States Supreme Court’s decision in Waller v. Georgia. View "Commonwealth v. Jones" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of extreme atrocity or cruelty. The Supreme Judicial Court vacated the judgment, holding (1) the evidence warranted an instruction on reasonable provocation, and counsel should have requested such an instruction; (2) the prosecutor committed error during closing argument; and (3) the cumulative effect of the prosecutor’s closing argument and trial counsel’s failure to request a voluntary manslaughter instruction based on reasonable provocation created a substantial likelihood of a miscarriage of justice and required that Defendant be given a new trial. The Court gave the Commonwealth the option of either accepting a reduction of the verdict of manslaughter or having the conviction vacated and proceeding with a new trial. View "Commonwealth v. Niemic" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. Defendant was sentenced to the mandatory sentence of life in prison without the possibility of parole. The Supreme Judicial Court affirmed Defendant’s conviction but remanded the case for resentencing, holding (1) the evidence was sufficient as a matter of law to support the conviction; (2) the verdict was not against the weight of the evidence and was consonant with justice; (3) Defendant’s claim that his right to a public trial was violated by the closure of the court room during jury empanelment was procedurally waived; (4) the trial judge erred by not instructing the jury regarding the risk of honest, but mistaken, eyewitness identification, but the error did not produce a substantial likelihood of a miscarriage of justice; (5) the prosecutor made improper statements during closing argument, but the prosecutor’s statements did not create a substantial likelihood of a miscarriage of justice; and (6) in accordance with Diatchenko v. District Attorney for the Suffolk Dist., Defendant was entitled to a reduction in sentence to life with the possibility of parole where he was seventeen years old at the time of the killing. View "Commonwealth v. Penn" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree and related charges. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) when assessed through the lens of Commonwealth v. Adjutant, the trial judge did not prejudicially err in excluding both evidence of the victim’s and his friends’ prior violent acts and statements Defendant made to his girl friend; (2) the judge did not err in denying Defendant’s postconviction motion for discovery of gang-related evidence; (3) the judge did not abuse his discretion in refusing to instruct the jury on manslaughter on theories of reasonable provocation and sudden combat; (4) Defendant did not receive ineffective assistance of counsel; (5) certain remarks made during the Commonwealth’s closing argument were improper, but the improper remarks did not create a substantial likelihood of a miscarriage of justice; and (6) there was not basis for exercising the Court’s authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict of murder to a lesser degree of guilt or order a new trial. View "Commonwealth v. Camacho" on Justia Law

Defendant was sentenced to committed time on a conviction. Defendant successfully moved to vacate community parole supervision for life and was resentenced to a term of probation. Defendant moved to vacate the condition of probation requiring GPS monitoring. The motion was denied. The Appeals Court affirmed. The Supreme Judicial Court granted Defendant’s application for further appellate review to address the propriety of resentencing Defendant by imposing a term of probation to run from and after committed sentences that either had fully been served at the time of resentencing or will have fully been served before the probationary term was due to begin. The Court affirmed the order denying Defendant’s motion to vacate the GPS condition of probation, holding (1) where a defendant sentenced to committed time on a conviction is resentenced to a term of probation, the new sentence violates double jeopardy where the defendant had already completed the original sentence on that conviction before the resentencing; and (2) where the defendant has yet to complete the original sentence on a conviction, resentencing to a term of probation does not violate double jeopardy provided that the total length of incarceration imposed on the defendant for that conviction is not increased. View "Commonwealth v. Sallop" on Justia Law

After a jury trial, Defendant was found guilty of rape of a child by force and of assault with intent to rape a second child. The Appeals Court affirmed. Defendant appealed, arguing that the admission of evidence relating to a prior acquittal deprived him of his right to a fair trial and due process. The Supreme Judicial Court reversed Defendant’s convictions, holding (1) there was no error in the admission of the evidence on relevancy grounds; but (2) the collateral estoppel protections necessarily embraced by article 12 of the Massachusetts Declaration of Rights warranted the exclusion of the acquittal evidence under the circumstances of this case. View "Commonwealth v. Dorazio" on Justia Law

Defendants were indicted on charges of unarmed robbery and assault and battery. Defendants both committed the offenses prior to their eighteenth birthdays. The Governor subsequently signed an “Act expanding juvenile jurisdiction” that extended the jurisdiction of the juvenile court to children who are seventeen years of age at the time of committing an offense. Defendants filed motions to dismiss, arguing that the Act should be applied retroactively to seventeen-year-old defendants who had criminal charges pending against them as of the Act’s effective date and that a failure to apply the Act retroactively as to such defendants would violate their equal protection rights. The Supreme Judicial Court held (1) the Act does not apply retroactively to a defendant who commits an offense prior to his eighteenth birthday for which a criminal proceeding commenced prior to the effective date of the Act; and (2) prospective application of the Act does not violate the equal protection guarantees provided by the Fourteenth Amendment to the federal Constitution and article 1 of the Massachusetts Declaration of Rights, as amended by article 106 of the Amendments. View "Commonwealth v. Freeman" on Justia Law

After a jury trial, Defendant was convicted of several crimes based on three incidents that occurred in October 2010 when Defendant accosted three different teenage victims as they walked to school. On appeal, Defendant argued, among other things, that the motion judge erred in denying his motion to suppress statements that he made to police during a videotaped interview. The Supreme Judicial Court reversed, holding that the statements at issue were erroneously admitted at trial because the police engaged in impermissibly coercive tactics that rendered Defendant’s statements involuntary under the circumstances of the interrogation, and the error was not harmless beyond a reasonable doubt. Remanded for a new trial. View "Commonwealth v. Monroe" on Justia Law