Justia Massachusetts Supreme Court Opinion Summaries

Defendant was convicted of murder in the second degree and received a mandatory sentence of life imprisonment with eligibility for parole after fifteen years. Defendant was fifteen years old at the time of the offense. Defendant appealed, arguing, among other things, that his mandatory life sentence constituted cruel and unusual punishment in violation of the Eighth Amendment to the U.S. Constitution and article 26 of the Massachusetts Declaration of Rights. The Supreme Judicial Court affirmed, holding (1) a mandatory life sentence with eligibility for parole after fifteen years for a juvenile homicide offender convicted of murder in the second degree does not offend the Eighth Amendment or article 26 or other constitutional rights; and (2) Defendant’s challenges to his underlying conviction were without merit. View "Commonwealth v. Okoro" on Justia Law

In 2013, Gregory Diatchenko filed the present action seeking a declaration that, because he was seventeen at the time he committed the offense leading to his conviction of murder in the first degree, his mandatory sentence of life without parole was unconstitutional. Following Miller v. Alabama, the Supreme Judicial Court determined that the mandatory imposition of such a sentence was unconstitutional. The Court held that a juvenile homicide offender who receives a mandatory sentence of life imprisonment must be afforded the opportunity for release on parole. Diatchenko and another petitioner, both of whom became immediately eligible for parole pursuant to the Court’s decision in Diatchenko I, contended that, to ensure their opportunity for release through parole was meaningful, they must have access to counsel, access to funds for counsel and for expert witnesses, and an opportunity for judicial review of the decision on their parole applications. The Supreme Judicial Court agreed with the petitioners, holding (1) the procedural protections of representation by counsel and the opportunity to obtain expert assistance in connection with that initial parole hearing are necessary for juvenile homicide offenders serving a mandatory life sentence; and (2) such offenders are entitled to limited judicial review of a parole board decision denying initial parole. View "Diatchenko v. District Attorney" on Justia Law

The chief of police of the city of Worcester determined that Appellant was not a “suitable person” under Mass. Gen. Laws. ch. 140, 131(d) and (f) to hold a license to carry firearms. The chief first suspended Appellant’s license then revoked the license and finally denied Appellant’s application for a new license to carry. Appellant filed a complaint for judicial review of the chief’s decisions. The district court litigation was consolidated and resolved largely in favor of Appellant. The chief sought certiorari review in the superior court, and the superior court granted the chief’s motion for judgment on the pleadings. The Supreme Judicial Court affirmed, holding (1) the “suitable person” standard does not violate the Second Amendment, either facially or as applied; (2) the statutory scheme as to the suspension and revocation of licenses and the denial of license applications does not violate procedural due process; (3) the “suitable person” standard is not unconstitutional as applied to Appellant; and (4) the decisions of the chief were supported by substantial evidence. View "Chief of Police v. Holden" on Justia Law

After a jury trial, Defendant was convicted of assault and battery by means of a dangerous weapon and assault and battery. Defendant appealed, arguing that the motion judge erred in denying a motion to suppress the victim’s out-of-court eyewitness identification, and (2) DNA evidence identifying the victim as the source of blood found on Defendant’s shirt should have been suppressed because the DNA analysis constituted a search that required a warrant. The Supreme Court affirmed, holding (1) although the victim had told the police that the assailant wore a gray shirt and Defendant was the only person shown wearing a gray shirt in the photographic array, the victim did not select the photograph on that basis, and therefore, the judge did not err in denying Defendant’s motion to suppress; and (2) where, as in this case, DNA analysis is limited to the creation of a DNA profile from lawfully seized evidence of a crime and the profile is used only to identify its unknown source, the DNA analysis is not a search within the meaning of the Fourth Amendment, and therefore, no search warrant was required to conduct the DNA analysis of the bloodstain from Defendant’s clothing in this case. View "Commonwealth v. Arzola" on Justia Law

Defendant was charged with possession of a stun gun in violation of Mass. Gen. Laws ch. 140, 131J, which bans the possession of an electrical weapon with some exceptions. Defendant filed a pretrial motion to dismiss the charge, arguing that a stun gun is an “arm” for purposes of the Second Amendment, and therefore, her possession of the stun gun was constitutionally protected. The motion was denied, and the trial judge found Defendant guilty of possession of the stun gun. The Supreme Court affirmed the conviction, holding that chapter 140 section 131J does not violate the Second Amendment right to bear arms, as a stun gun is not the type of weapon that is eligible for Second Amendment protection. View "Commonwealth v. Caetano" on Justia Law

After a jury trial, Defendant was convicted of murder in the second degree and of possession of a firearm without a license. Defendant appealed, arguing that his attorney’s concession in opening statement and closing argument that Defendant committed the killing was tantamount to a guilty plea and that because a colloquy did not take place between the judge and Defendant as to whether Defendant made the concession knowingly and voluntarily, he was entitled to a new trial. The Supreme Judicial Court affirmed the convictions, holding (1) no colloquy was required regarding defense counsel’s concession of guilt to the lesser included offense of manslaughter; and (2) because Defendant did not claim on appeal that he received ineffective assistance of counsel, there was no basis on which to vacate Defendant’s convictions. View "Commonwealth v. Evelyn" on Justia Law

Police officers stopped Defendant for driving with an unilluminated headlight. During the stop, the officers saw in the vehicle a one-ounce bag of marijuana. The officers ordered Defendant out of the vehicle and conducted a search of the vehicle in which they discovered two other bags of marijuana. Defendant was booked on charges of possession of marijuana with intent to distribute. The officers seized and searched Defendant’s cellular telephone, finding text messages they identified as being consistent with sales of marijuana. Defendant moved to suppress the marijuana found in his vehicle and the text messages discovered on his phone on the grounds that “police observation of one ounce or less of marijuana is insufficient, by itself, to give rise to the probable cause necessary to conduct a search.” The district court denied the motion to suppress, concluding that the officers were permitted to enter the vehicle to effect the forfeiture of the marijuana they saw. The Supreme Court reversed, holding that the officers’ entry into the vehicle was impermissible because they lacked probable cause to believe the vehicle contained evidence of a crime, and therefore, the evidence obtained as a result of the searches of Defendant’s vehicle and of his cellular telephone must be suppressed. View "Commonwealth v. Sheridan" on Justia Law

Defendant was indicted on a charge of receiving a stolen motor vehicle. Defendant moved to suppress evidence seized as a result of a warrantless search of his garage. A superior court judge denied the motion. After a joint trial of Defendant and his codefendant, Defendant was convicted. The Supreme Judicial Court affirmed, holding (1) the superior court judge did not err in denying Defendant’s motion to suppress, as the warrantless entry into the garage was justified by exigent circumstances; (2) the trial court did not err in admitting recordings of jailhouse telephone calls between Defendant and his codefendant; and (3) the evidence was sufficient to support Defendant’s conviction. View "Commonwealth v. Ramos" on Justia Law

After a jury trial, Defendant was convicted of intimidating a witness, carrying a firearm without a license, discharging a firearm within 500 feet of a building, and assault by means of a dangerous weapon. The Supreme Judicial Court vacated the convictions and remanded for a new trial, holding that the trial judge (1) did not abuse his discretion in admitting two photographs of a handgun that looked like the unrecovered handgun fired by Defendant; (2) did not err in denying Defendant’s motion for a required finding of not guilty; but (3) erred in allowing the Commonwealth to present a witness’s prior recorded testimony without sufficient proof of the witness’s unavailability, and the error was not harmless beyond a reasonable doubt. View "Commonwealth v. Housewright" on Justia Law

A juvenile was charged with possession of a class D substance with the intent to distribute marijuana after a street encounter during which a police officer arrested the juvenile. A judge in the juvenile court allowed the juvenile’s motion to dismiss the complaint for lack of probable cause. The court of appeals reversed. The Supreme Judicial Court reversed the court of appeals and affirmed the juvenile court’s order of dismissal, holding that, under the totality of the circumstances, the complaint application in this case did not allege facts sufficient to establish probable cause as to each element of the offense charged. View "Commonwealth v. Ilya I." on Justia Law