Justia Massachusetts Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of murder in the second degree. A panels of the Appeals Court affirmed Defendant’s conviction. The Supreme Judicial Court affirmed, holding (1) the superior court did not err in denying Defendant’s motion to dismiss for lack of a speedy trial under Mass. R. Crim. P. 36 because Defendant acquiesced in certain delays, failed to object to every continuance sought by the Commonwealth, did not press a motion to compel the production of mandatory discovery, and otherwise engaged in ordinary motion practice; and (2) the prosecutor made improper remarks during closing argument, but the remarks did not constitute reversible error. View "Commonwealth v. Taylor" on Justia Law

Defendant pleaded guilty to eleven counts of possessing child pornography, one of the sex offenses enumerated in Mass. Gen. Laws ch. 265, 47 that requires a defendant convicted of such an offense to be subject to global positioning system (GPS) monitoring as a condition of any term of probation. Such monitoring was not imposed as part of Defendant’s sentence. Almost one year after Defendant was sentenced, the Commonwealth sought correction of Defendant’s sentence by the addition of GPS monitoring as a condition of Defendant’s sentence. The sentencing judge allowed the Commonwealth’s motion. Defendant subsequently filed a motion to vacate the modified sentence, arguing, among other things, that the delayed imposition of GPS monitoring violated the prohibition against double jeopardy. Defendant’s motion was denied. The Supreme Judicial Court vacated the order imposing GPS monitoring on Defendant, holding (1) Defendant’s initial sentence was illegal insofar as it did not include GPS monitoring as a condition of Defendant’s probation; but (2) under the circumstances of this case, the belated correction of Defendant’s sentence contravened Defendant’s legitimate expectation of finality in the terms of his initial sentence in violation of principles of double jeopardy. View "Commonwealth v. Selavka" on Justia Law

Defendant pleaded guilty to several offenses, including the dissemination of visual material depicting a child in a state of nudity or sexual conduct, one of the sex offenses involving a child enumerated in Mass. Gen. Laws. ch. 265, 47 that requires a defendant convicted of such an offense to be subject to global positioning system (GPS) monitoring as a condition of any term of probation. The sentencing judge in this case declined to require that Defendant wear a GPS device as a condition of probation. The Supreme Judicial Court reversed, holding that the failure to include GPS monitoring as a condition of Defendant’s probation was error, where (1) a sentencing judge has no discretion whether to impose GPS monitoring on a defendant sentenced to a probationary term for an enumerated offense; and (2) Mass. Gen. Laws ch. 265, 47 does not violate Defendant’s due process rights. View "Commonwealth v. Guzman" on Justia Law

A homeless man died after being stabbed in the alcove of a storefront. Two young women identified Defendant as the perpetrator. Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. Defendant was sentenced to life imprisonment. The Supreme Judicial Court affirmed the conviction, holding (1) the trial judge did not err in permitting the introduction of state of mind evidence where the judge provided numerous limiting instructions; (2) the trial judge did not err in denying Defendant’s motion to suppress identifications and his motion for a required finding of not guilty; (3) Defendant was not denied timely access to footage of surveillance videotapes in a way that prejudiced the preparation of his defense; (4) the trial judge did not abuse her discretion in denying Defendant’s request to recall the two percipient witnesses; and (5) Defendant’s claim that the Commonwealth knowingly procured false testimony was without merit. View "Commonwealth v. Forte" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on theories of deliberate premeditation, extreme atrocity or cruelty, and felony murder. Defendant appealed, arguing, among other things, that in litigating his motions to suppress, he should have been afforded “target standing” to challenge the violation of his alleged coventurers’ constitutional rights. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) even assuming the availability of target standing, Defendant was properly denied target standing to challenge the violations of his coventurers’ constitutional rights; (2) the witness immunity statute was constitutional as applied to Defendant; (3) certain identification testimony was improperly admitted into evidence, but the improper testimony was not prejudicial; and (4) the trial judge erred in failing to give an instruction pursuant to Commonwealth v. DiGiambattista, but the error was not prejudicial. View "Commonwealth v. Vacher" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. Defendant filed a motion for a new trial, asserting multiple claims of ineffective assistance of counsel, and requested an evidentiary hearing. The trial judge denied the motion without a hearing. The Supreme Judicial Court affirmed Defendant’s conviction and the denial of Defendant’s motion for a new trial, holding (1) Defendant failed to establish that his trial counsel provided ineffective assistance; (2) the trial judge did not err in denying Defendant an evidentiary hearing on his motion for a new trial; and (3) there was no substantial likelihood of a miscarriage of justice in the trial judge’s failure to make written findings. View "Commonwealth v. Torres" on Justia Law

After Defendant’s first three trials ended in mistrials, a fourth trial was held, and Defendant was convicted of murder in the first degree on theories of felony-murder and extreme atrocity or cruelty. Defendant appealed, raising numerous claims of error. The Supreme Court affirmed the convictions, holding (1) the trial court did not commit prejudicial error in its evidentiary rulings; (2) any error committed by the prosecutor during closing argument was not prejudicial; (3) the trial judge did not err in denying Defendant’s motion to dismiss the indictments against him; and (4) the Commonwealth engaged in egregious misconduct by issuing a press release regarding the case, but the conduct was not of sufficient significance to result in the denial of Defendant’s right to a fair trial. The Court also reinstated Defendant’s two convictions of armed robbery - the underlying felonies in the felony-murder conviction - which the trial judge had dismissed as duplicative, holding that those convictions were not duplicative where Defendant was also convicted on another theory of murder in the first degree - murder with extreme atrocity or cruelty. View "Commonwealth v. Wood" on Justia Law

Defendant was stopped by police officers while walking down the street. An officer asked for permission to search the backpack Defendant was carrying, whereupon Defendant removed the bag and handed it to the officer. The officer then removed a box designed to look like a cigarette package but which was “noticeably heavier.” At this time, Defendant changed his mind and told the officer he could not look in the bag. The officer proceeded to open the box and discovered cocaine. Defendant filed a motion to suppress the evidence seized as a result of his stop and subsequent arrest. The trial court denied the motion, and the court of appeals affirmed. Defendant was subsequently convicted of possession of cocaine with intent to distribute. Defendant appealed the denial of his motion to suppress. The Supreme Court vacated the conviction and ordered a new trial, holding (1) the investigatory stop of Defendant was supported by reasonable suspicion; but (2) there was no probable cause to make an arrest when the cigarette box was opened, and the opening of the cigarette box could not be justified as a search incident to arrest. View "Commonwealth v. Stewart" on Justia Law

Plaintiff filed a complaint in federal court against the Trustees of the Boston Public Library and a library employee alleging that he was denied entrance to the Boston Public Library in violation of his civil rights. The district court denied Plaintiff’s motion seeking disqualification of the Boston Law Department as counsel for Defendants, concluding that the Trustees constitute a municipal entity that oversees the Library as a department of the City of Boston. Plaintiff subsequently filed this action in the county court seeking a judgment declaring that the Trustees and the City “are two separate, independent legal entities,” and that the Law Department may not provide legal representation to the Trustees or Library employees. A single justice of the Supreme Judicial Court dismissed the complaint and denied postjudgment relief. The Supreme Judicial Court affirmed, holding that because the complaint in this case dealt with the same controversy that existed between the parties in the federal litigation, it did not present a proper occasion for declaratory relief. View "Lu v. City of Boston" on Justia Law

Law enforcement officers stopped the vehicle Defendant was driving and placed Defendant under arrest on outstanding arrest warrants. The officers proceeded to pat frisk Defendant’s outer clothing and opened a container found on Defendant. Before transporting Defendant to the station for booking, an officer entered Defendant’s vehicle to retrieve its keys and saw an unlabeled container in plain view. The officer seized the pills contained in the container. Thereafter, Defendant was charged with illegal possession of methadone. Defendant moved to suppress the evidence seized as a result of his arrest on the outstanding warrants. The district court denied the motion, and the Appeals Court affirmed. The Supreme Judicial Court reversed the denial of Defendant’s motion to suppress, vacated Defendant’s conviction, and remanded for a new trial, holding that, under the circumstances of this case, the police exceeded the lawful scope of a search incident to arrest, an inventory search, and a seizure under the plain view doctrine. View "Commonwealth v. White" on Justia Law