Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty, and of unlawful possession of a firearm. The Supreme Judicial Court affirmed Defendant’s convictions and the denial of his motions for a new trial and discerned no basis to reduce the verdict or to order a new trial pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) defense counsel was not ineffective for failing to object when court officers excluded the public and Defendant’s family from the courtroom during jury empanelment; (2) Defendant waived his right to be present at sidebar discussions during jury empanelment; (3) the trial judge acted within his discretion in deciding not to allow Defendant’s peremptory challenges of three African-American jurors; (4) Defendant’s challenges to the trial judge’s evidentiary rulings were without merit; (5) the prosecutor did not impermissibly bolster the creditability of certain witnesses or commit prejudicial error during closing argument; (6) no substantial likelihood of a miscarriage of justice occurred when the judge instructed the jury; and (7) Defendant’s motion for a new trial was properly denied. View "Commonwealth v. Fritz" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. Defendant’s motion for a new trial was denied. The Supreme Judicial Court affirmed Defendant’s convictions and the denial of his motion for a new trial and discerned no basis to exercise its authority pursuant to Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not err in allowing multiple prior consistent statements; (2) trial counsel was not ineffective in failing to object to the admission of certain evidence and failing to impeach a witness; (3) there was not improper prosecutorial vouching during closing argument that created a substantial likelihood of a miscarriage of justice; and (4) the conviction was viable despite the uncorroborated testimony of a cooperating witness, and newly discovered evidence did not necessitate a new trial. View "Commonwealth v. Lessieur" on Justia Law

After a jury trial, Defendant was convicted of murder in the second degree, unlawful possession of a firearm, unlawful possession of a loaded firearm, and unlawful possession of ammunition. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) the trial judge’s refusal to grant immunity to two potential defense witnesses did not violate Defendant’s right to a fair trial and due process of law, nor his right to present a complete defense; and (2) the prosecutor did not engage in improper vouching or misstate the evidence in during closing arguments. View "Commonwealth v. Brewer" on Justia Law

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