Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder in the first degree on a theory of extreme atrocity or cruelty for the murder of his four-year-old daughter, who died from intoxication due to sedating drugs found in her system, or from pneumonia, or from a combination of both intoxication and pneumonia. Defendant appealed his conviction and the denial of his motions for a new trial and for funds to retain a toxicologist. The Supreme Judicial Court affirmed the conviction and the orders denying Defendant’s motions, holding (1) the trial judge did not abuse his discretion in denying Defendant’s claim that his counsel was ineffective in handling the issue of toxicological evidence at trial, and trial counsel did not otherwise render ineffective assistance; (2) the evidence of malice was sufficient to support the conviction; (3) the prosecutor properly used and commented on evidence of acts Defendant committed after the charged offense to show intent or state of mind at the time of the charged offense; and (4) the trial judge did not err in denying Defendant’s motion for a new trial without an evidentiary hearing and in denying Defendant’s posttrial motion for funds to retain a forensic toxicologist.View "Commonwealth v. Riley" on Justia Law

The Department of Public Utilities imposed on Petitioners, electric companies, monetary assessments for the Storm Trust Fund (“assessment”) pursuant to Mass. Gen. Laws ch. 25, 12P, 18, which specifically prohibited Petitioners from seeking recovery of the assessment in any rate proceeding. Petitioners challenged the constitutionality of the recovery prohibition, both as required by the statute and impose by the Department’s order, claiming it was an unconstitutional taking. The Supreme Judicial Court affirmed the Department’s order, holding (1) the mere obligation to pay the assessment, regardless of whether recovery was permitted or precluded, did not rise to the level of a compensable per se taking; (2) Petitioner’s claim that the assessment constituted a taking by way of a confiscatory rate was inadequate on the facts as presented to the Court; and (3) the Department’s order imposing the assessment and articulating the recovery prohibition did not constitute a regulatory taking because the order simply required Petitioners to pay an assessment that served a legitimate public purpose and did not interfere with Petitioners’ overall property rights.View "Fitchburg Gas & Elec. Light Co. v. Dep’t of Pub. Utils." on Justia Law

After receiving a telephone call from Defendant’s neighbor, police entered Defendant’s front yard without a warrant and seized three dogs, two of which appeared to be dead, that had been left outside in severely inclement winter weather. Defendant was subsequently charged with three counts of animal cruelty. Defendant filed a motion to suppress the evidence obtained as a result of the warrantless search. The superior court granted the motion but reported the question of law to the Supreme Judicial Court of whether the ‘pure emergency’ exception to the warrant requirement extends to animals. The Court answered the question in the affirmative, holding that the emergency aid exception to the warrant requirement extends to police action undertaken to render emergency assistance to animals. Remanded.View "Commonwealth v. Duncan" on Justia Law

In 2010, Defendant, who was known to be associated with a gang, was indicted for the murder of a fourteen-year-old and the wounding of a fifteen-year-old. The Commonwealth, which believed the murder was committed in connection with the gang’s criminal activities, obtained from a cooperating witness a surreptitiously recorded conversation between Defendant and other gang members, during which Defendant admitted to the killing. Defendant sought to suppress the recorded conversation as well as statements he made to the police during a post-arrest interview. The superior court denied Defendant’s motion to suppress as to all of his statements. The Supreme Judicial Court (1) affirmed the denial of the motion to suppress with respect to Defendant’s recorded conversation; but (2) reversed the denial with respect to statements Defendant made during the custodial interview after clearly invoking his right to remain silent.View "Commonwealth v. Hearns" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony-murder, and related crimes. The Supreme Judicial Court affirmed the judgments of conviction and declined to reduce the degree of guilt or order a new trial pursuant to the Court’s power under Mass. Gen. Laws ch. 278, 33E, holding (1) the trial judge did not err in its evidentiary rulings; (2) Defendant’s counsel rendered effective assistance; (3) the prosecutor did not engage in prosecutorial misconduct; and (4) the trial judge did not err in instructing the jury. View "Commonwealth v. Johnston" on Justia Law

After a jury trial, Defendant was convicted of rape. Defendant’s appeal centered on his argument that the victim, an undocumented immigrant, characterized her consensual sex with Defendant as rape in her report to police to obtain immigration benefits. Specifically, Defendant claimed (1) he was denied the right to impeach the victim with evidence of a prior incident of sexual assault, after which she received a temporary work authorization; and (2) he should have been allowed to access Boston Area Rape Crisis Center (BARCC) records concerning the victim. The Supreme Judicial Court affirmed, holding (1) the trial judge properly determined that the probative value of any testimony concerning the prior incident of sexual assault would be outweighed by its prejudicial impact; and (2) Defendant did not make the necessary threshold showing that he was entitled to production of BARCC records.View "Commonwealth v. Sealy" on Justia Law

Defendant was convicted of murder in the first degree on the theories of premeditation and extreme atrocity or cruelty. Defendant’s defense was that a third party killed the victim while Defendant was unconscious due to severe intoxication. The Supreme Judicial Court affirmed Defendant’s conviction, holding (1) any prejudice in the admission into evidence of recorded telephone calls made on the day of the murder between Defendant and his girlfriend was cured by the judge; (2) the admission of a medical record showing that Defendant tested negative for any drugs was error, but Defendant suffered no risk of a miscarriage of justice; (3) counsel did not provide ineffective assistance; (4) the trial judge did not err in instructing the jury that there is no “legal limit” of intoxication for any purposes other than determining whether one is guilty of operating a motor vehicle while under the influence of alcohol; and (5) Defendant’s claim that his right to a public trial during jury empaneled was violated was waived. View "Commonwealth v. Wall" on Justia Law

After a jury trial, Defendant was convicted of attempted kidnapping and of accosting or annoying a person of the opposite sex. The Appeals Court reversed the judgment on the indictment charging accosting or annoying a person of the opposite sex, concluding that because the Commonwealth failed to demonstrate that Defendant’s conduct involved “sexually explicit language or acts,” the Commonwealth did not meet its burden of proving that Defendant’s conduct was “offensive.” The Supreme Judicial affirmed the judgment of conviction on the indictment charging accosting or annoying a person of the opposite sex, holding (1) the jury properly could have found the elements of accosting or annoying a person of the opposite sex beyond a reasonable doubt; and (2) Defendant’s counsel provided effective assistance pertaining to his conviction of accosting or annoying a person of the opposite sex. View "Commonwealth v. Sullivan" on Justia Law

After a jury trial, Defendant was convicted of aggravated kidnapping, aggravated rape, armed robbery, and related offenses. On appeal, Defendant argued that the prosecutor’s several references to his initial invocation of his right to remain silent violated his constitutional due process rights. The Appeals Court affirmed Defendant’s convictions. The Supreme Judicial Court affirmed, holding (1) the prosecutor’s references to Defendant’s invocation of his rights as set forth in Miranda v. Arizona at trial constituted error; but (2) under the circumstances of this case, the improper references did not raise a substantial risk of a miscarriage of justice. View "Commonwealth v. Letkowski" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation, arson of a dwelling house, and attempted murder of thirteen persons arising from Defendant’s act of setting fire to a curtain in the first-floor apartment of a three-story house. The Supreme Judicial Court vacated in part and affirmed in part, holding that the trial judge erred in denying Defendant’s motion to suppress certain statements she made to police during two interviews, and the error was not harmless with respect to the convictions of murder in the first degree and attempted murder but was harmless with respect to the conviction of arson of a dwelling house. Remanded. View "Commonwealth v. Thomas" on Justia Law