Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions for four counts of murder in the first degree on the theory of felony-murder and the order denying his motion for a new trial and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Judicial Court held (1) the judge did not abuse his discretion in denying Defendant's motion for a new trial; (2) Defendant's trial counsel did not provide ineffective assistance of counsel; (3) Defendant's argument that exculpatory evidence pointed to another suspect was unavailing; (4) the prosecutor did not commit misconduct during closing arguments; and (5) the judge did not abuse his discretion in declining to strike a juror. View "Commonwealth v. Moore" on Justia Law

The Supreme Judicial Court affirmed the judgment of a superior court judge denying the special motion to dismiss under Mass. Gen. Laws ch. 231, 59H, the anti-SLAPP statute, filed by Exxon Mobil Corporation in this civil enforcement action brought by the Attorney General, holding that the anti-SLAPP statute does not apply to civil enforcement actions by the Attorney General.The Attorney General brought this action against Exxon Mobil for various alleged violations of Mass. Gen. Laws ch. 93A based on the company's communications regarding the impact of climate change with investors and consumers. Exxon Mobil filed an anti-SLAPP motion, asserting that the action was motivated by its "petitioning" activity. The superior court judge denied the motion on the ground that at least some of the activity alleged in the complaint was not "petitioning" under the statute. The Supreme Judicial Court affirmed on an alternate ground, holding that Mass. Gen. Laws ch. 231, 59H does not apply to civil enforcement actions brought by the Attorney General. View "Commonwealth v. Exxon Mobil Corp." on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of felony-murder in the first degree and the denial of his motion for a new trial, holding that there was no error that would necessitate a new trial, and there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or to reduce the conviction to a lesser degree of guilt.On appeal, Defendant argued, among other things, that his felony-murder conviction must be reversed because his accomplice was killed during a struggle with the intended robbery victim, and therefore, the theory of felony-murder was inapplicable. The Supreme Judicial Court affirmed, holding (1) the felony-murder rule was applicable; (2) the evidence was sufficient to support Defendant's convictions; and (3) Defendant's remaining assignments of error were without merit. View "Commonwealth v. Duke" on Justia Law

The Supreme Judicial Court held that the superior court erred in denying Defendant's motion to dismiss insofar as it concerned the charge of murder in the first degree on a joint venture theory, holding that there was insufficient evidence to support this conviction.Defendant charged with murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty, accessory after the fact to murder, carrying a firearm without a license, and carrying a loaded firearm without a license. After four days of deliberations the jury deadlocked, and the trial judge declared a mistrial. Defendant then filed a motion to dismiss, arguing that a retrial would violate his right against double jeopardy. After the motion judge denied the motion Defendant filed a petition pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court remanded the cause, holding that there was insufficient evidence that Defendant shared the lethal intent of the shooter required to support a conviction of murder in the first degree on a joint venture theory. View "Baxter v. Commonwealth" on Justia Law

The Supreme Judicial Court held that "tower dumps" are not per se unconstitutional and that investigators may use tower dumps so long as they comply with the warrant requirements of article 14 of the Massachusetts Declaration of Rights.The Commonwealth obtained search warrants for seven different "tower dumps," a law enforcement tool that provides investigators with the cell site location information for all devices that connected to specific cell towers during a particular time frame, corresponding to the locations of several crimes. Defendant was ultimately charged with six robberies and a homicide. Defendant moved to suppress all evidence obtained from the tower dumps as the fruit of an unconstitutional search. The superior court judge denied the motion. The Supreme Judicial Court reversed in part, holding (1) investigators may use tower dumps so long as they comply with the warrant requirements of article 14; (2) the second of the two warrants in this case was supported by probable cause and therefore did not offend the Massachusetts Declaration of Rights; but (3) the first warrant was not supported by probable cause, and any evidence obtained from it must be suppressed. View "Commonwealth v. Perry" on Justia Law

The Supreme Judicial Court vacated the order of the superior court judge allowing the forfeiture in this case, holding that firearms found to be improperly secured according to the requirements of Mass. Gen. Laws ch. 140, 131L are not subject to forfeiture under Mass. Gen. Laws ch. 276, 3(b), which regulates the disposal of certain firearms seized during the execution of a search warrant.Police obtained a search warrant to search Defendant's home for a firearm allegedly used in an altercation. During the search, officers found that some of Defendant's more than 240 firearms appeared to be improperly secured. Defendant was subsequently indicted on twenty-seven counts of improperly securing a firearm and convicted on twelve counts. Defendant later moved for the return of all twenty-seven of the seized firearms. A superior court judge ordered the return of the firearms seized during during the execution of the search warrant with the exception of the twelve that had been found to have been improperly secured, which the judge ordered be forfeited and destroyed. The Court of Appeals vacated the order below, holding that Mass. Gen. Laws ch. 140, 129D applies only to firearms "deliver[ed] or surrender[ed]," not to those seized during a lawful search. View "Commonwealth v. Fleury" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of carrying a firearm without a license, holding that the trial court erred in denying Defendant's motion to suppress.At issue was whether police officers may conduct a traffic stop on the basis of a traffic violation after having resolved the violation at a prior encounter, then having allowed the vehicle to leave, without any other traffic violation taking place. Defendant challenged the constitutionality of the traffic stop in this case under article 14 of the Massachusetts Declaration of Rights. The Supreme Judicial Court reversed the judgment of the trial court denying Defendant's motion to suppress and vacated his conviction, holding (1) police may not conduct a traffic stop on the basis of a traffic violation after having previously addressed the violation and having resolved the issue in a separate, discrete encounter; and (2) in the instant case, police lacked the authority to conduct the second traffic stop, and therefore, the stop was unreasonable under article 14. View "Commonwealth v. Daveiga" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of possessing a firearm without a license and possessing a large capacity feeding device, holding that Defendant's arguments on appeal were without merit.On appeal, Defendant argued that the trial court erred by failing to suppress the firearm and the attached large capacity feeding device as the fruits of a warrantless search and that there was insufficient evidence to support the convictions. The Supreme Judicial Court affirmed, holding (1) the motion judge did not err in denying Defendant's motion to suppress; and (2) there was sufficient evidence that Defendant possessed the firearm in question. View "Commonwealth v. DeJesus" on Justia Law

The Supreme Court reversed the judgment of the trial court allowing Defendant's second motion for a new trial based on constitutionally ineffective assistance of counsel at trial, holding that Defendant's trial counsel did not provide ineffective assistance.After a jury trial, Defendant was convicted of murder in the first degree and unlawful possession of a firearm. The Supreme Court remanded the case for an evidentiary hearing on the sole issue of trial counsel's performance. Before an evidentiary hearing was held on remand, Defendant's appellate counsel filed a second motion for a new trial on the ground that trial counsel had provided ineffective assistance. The trial court allowed the motion. The Supreme Court reversed, holding that it was an abuse of discretion to hold that trial counsel provided constitutionally ineffective assistance. View "Commonwealth v. Ng" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of extreme atrocity or cruelty for the killing of his wife, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the prosecutor did not improperly exercise a peremptory challenge to strike a male juror; (2) the trial judge did not abuse her discretion in connection with certain evidentiary decisions; (3) the prosecutor's challenged statements in his closing argument did not create a substantial likelihood of a miscarriage of justice; (4) the jury instruction on mental impairment was sufficient; (5) the denial of Defendant's motion for a new trial did not constitute an abuse of discretion; and (6) this Court declines to exercise its authority under Mass. Gen. Laws 278, 33E, to order a new trial or a reduction in the verdict. View "Commonwealth v. Huang" on Justia Law