Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the first degree on the theory of felony-murder. Defendant appealed, arguing, inter alia, that the trial court erred in its partial denial of his motion to suppress statements he made after being taken involuntarily into the police station. The Supreme Judicial Court affirmed, holding (1) Defendant’s motion to suppress should have been allowed in its entirety because these statements were the inadmissible fruits of an unlawful arrest, but the error did not create a substantial likelihood of a miscarriage of justice; (2) the trial court did not err in denying defense counsel’s motion to withdraw from the case two days before trial; and (3) Defendant’s claim that his counsel provided ineffective assistance lacked merit. View "Commonwealth v. Melo" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. Defendant filed a motion for a new trial, asserting that his trial counsel provided ineffective assistance. The trial judge denied the motion. The Supreme Judicial Court vacated Defendant’s conviction and remanded for a new trial, holding that Defendant’s counsel did not prepare for trial in an adequate manner and that counsel’s deficient performance at trial, where Defendant’s defense was presented “poorly and incompletely,” created a substantial likelihood of a miscarriage of justice. View "Commonwealth v. Alcide" on Justia Law

After a jury trial, Defendant was convicted of deliberately premeditated murder. On appeal, Defendant filed a motion for a new trial and a motion for funds for an investigator. The trial judge denied the motions without a hearing and also denied Defendant’s motion for reconsideration. The Supreme Judicial Court affirmed the convictions and the denial of Defendant’s postconviction motions, holding (1) the judge did not abuse his discretion in concluding that Defendant failed to meet his burden of proof when he denied Defendant’s claim of ineffective assistance of counsel as contained in his motions for a new trial and for reconsideration; and (2) the judge’s conclusion that Defendant’s claim of newly discovered evidence could not be ascertained was neither erroneous nor an abuse of discretion. View "Commonwealth v. Gorham" on Justia Law

The Town of Mendon adopted a bylaw prohibiting the sale or presence of alcohol at adult entertainment establishments. Showtime Entertainment, LLC, which sought to operate an adult entertainment establishment within the Town and to serve alcohol on the premises, brought suit in federal court seeking to invalidate the bylaw. The United States Court of Appeals for the First Circuit certified questions to the Supreme Judicial Court focusing on parts of the test employed to determine the constitutionality of “content-neutral” restrictions on expressive behavior as first outlined in United States v. O’Brien. The Supreme Judicial Court answered (1) the Town in this case utilized evidence sufficient to demonstrate a countervailing State interest to justify the restriction at issue; but (2) the bylaw was not adequately tailored to pursue the Town’s goal of crime prevention. View "Showtime Ent., LLC v. Town of Mendon" on Justia Law

A Massachusetts grand jury issued indictments against Defendants, Nickoyan Wallace and Timi Wallace, accusing them of murder. Defendants were in federal custody from 2000 until 2009. Not until 2009 did prosecutors initiate the necessary steps to gain custody of Defendants from federal prison authorities under the Interstate Agreement on Detainers. Defendants were subsequently arraigned in superior court. Defendants filed motions to dismiss, alleging that the Commonwealth’s delay in obtaining custody of them from federal prison authorities impermissibility affected their right to a speedy trial. A superior court judge found that Timi’s right to a speedy trial had not been violated but that of Nickoyan had. The Appeals Court affirmed in part and reversed in part, concluding that the Commonwealth had not violated the speedy trial right of either defendant. The Supreme Judicial Court affirmed the trial court’s decision to deny Timi’s motion and to allow Nickoyan’s motion, holding that, under the circumstances of this case, Nickoyan’s right to a speedy trial was violated under the circumstances of this case but that Timi’s was not. View "Commonwealth v. Wallace" on Justia Law

Defendant was indicted on four counts of forcible rape of a child and four counts of indecent assault and battery on a child under the age of fourteen. Defendant filed a motion to suppress statements he made to police officers during the course of two interviews, the first being prearrest and the second following his arrest. Defendant was advised of his Miranda rights at the beginning of both interviews, but those rights were not accurately explained. The district court suppressed both statements. The Supreme Court reversed the suppression of the prearrest statement but affirmed the suppression of the postarrest statement, holding (1) the totality of the circumstances supports the conclusion that Defendant’s prearrest statements were voluntary; and (2) the Commonwealth failed to meet its burden of proving that Defendant waived his right to consult with counsel prior to giving his postarrest statements. View "Commonwealth v. Libby" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. Defendant appealed. While his appeal was pending, Defendant filed a motion for a new trial, arguing that his trial counsel provided ineffective assistance and that the trial court erred in instructing the jury. The judge granted Defendant’s motion for a new trial, concluding that Defendant’s trial counsel was ineffective in failing to fully investigate, present, and argue evidence of Defendant’s mental condition. The Supreme Judicial Court reversed, holding that the judge erred in ruling that counsel’s strategic choice to forgo further investigation of Defendant’s mental condition and to present only an intoxication defense was manifestly unreasonable. View "Commonwealth v. Kolenovic" on Justia Law

Christopher Kostka’s twin brother, Timothy Kostka, was indicted on charges of murder in the first degree and armed home invasion. The Commonwealth filed a motion to compel Christopher to provide a saliva sample from which it may obtain Christopher’s DNA, arguing that the DNA sample was necessary in order to determine whether Christopher was the identical or fraternal twin of Timothy. The trial judge allowed the motion, concluding that the DNA sample was relevant to establishing whether the DNA found under the victim’s fingernails matched Christopher’s and that a sample of Christopher’s DNA would “probably” provide evidence relevant to the question of Timothy’s guilt. Christopher refused to comply with the order to compel, and a judgment of contempt was entered against him. The Supreme Judicial Court reversed, holding that Christopher’s DNA was not shown to be sufficiently relevant or important to the question of Timothy’s guilt or innocence so as to outweigh the constitutional rights of Christopher, an uncharged third party in the criminal proceeding. View "Commonwealth v. Kostka" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. Defendant was sixteen years old at the time of the murder. Defendant subsequently filed a motion to reduce the verdict to murder in the second degree. The trial judge granted the motion. After Defendant was resentenced, he filed a notice of appeal. Defendant then filed a motion for a new trial arguing that his Sixth Amendment right to a public trial was violated when the courtroom was closed during jury empanelment. The motion was denied, and Defendant appealed. The Supreme Judicial Court affirmed, holding that the lower court (1) did not err in reducing the verdict to murder in the second degree based on the facts of this case; and (2) did not err in failing to instruct the jury on involuntary manslaughter based on Defendant’s mental impairment of ADHD and depression in an adolescent brain. View "Commonwealth v. Pagan" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. Defendant filed a direct appeal and also appealed the denial of his motion for a new trial. The Supreme Judicial Court affirmed the conviction and the order denying Defendant’s motion for a new trial and declined to exercise its power under Mass. Gen. Laws ch. 278, 33E, holding (1) the judge considering Defendant’s motion for a new trial did not abuse its discretion in denying the motion without an evidentiary hearing; (2) assuming, without deciding, that the Commonwealth failed to timely disclose exculpatory evidence, the nondisclosure did not result in a substantial likelihood of a miscarriage of justice; (3) the prosecutor did not commit prosecutorial misconduct; and (4) Defendant’s trial counsel did not provide ineffective assistance. View "Commonwealth v. Vaughn" on Justia Law