Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the superior court judge denying Defendant's motion to suppress a video recording Defendant published to his social media account that showed an individual seen from the chest down holding what appeared to be a firearm, holding that no search in the constitutional sense occurred.After accepting a friend request from an undercover police officer, Defendant published the video at issue to his social media account. The officer made a recording of the posting, and that recording was used in the criminal proceedings against Defendant. The trial judge concluded that no search had occurred and denied Defendant's motion to suppress. The Supreme Court affirmed, holding that Defendant did not retain a reasonable expectation of privacy in his social media stories. View "Commonwealth v. Carrasquillo" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for two counts of armed assault with intent to murder and other crimes, holding that denying superior court defendants the statutory right to a defendant-capped plea does not violate equal protection principles under either the Federal or State Constitutions.Defendant was charged, pleaded guilty, and was sentenced in the superior court. Defendant sought to withdraw his plea on the basis of a facial challenge to the procedural scheme laid out in Mass. Gen. Laws ch. 278, 18 and rule 12(c)(4)(A), arguing that denying superior court defendants the statutory right to a defendant-capped plea violates constitutional equal protection principles. The Supreme Judicial Court affirmed, holding that the procedural scheme of Mass. Gen. Laws ch. 278, 18 and Mass. R. Crim. P. 12 survives rational basis scrutiny. View "Commonwealth v. Roman" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for simple assault and battery, holding that while Defendant's bench trial, conducted partly via Zoom, did not violate Defendant's constitutional rights, this opinion sets forth guidelines to be followed when remote bench trials are contemplated in criminal cases.Defendant's bench trial was in the midst of the COVID-19 pandemic over an Internet-based video conferencing platform. On appeal, Defendant argued that his trial violated his constitutional rights to confront the witnesses against him, to be present at trial, to have a public trial, and to have effective assistance of counsel. The Supreme Judicial Court affirmed, holding that Defendant was not prejudiced by his appearance over Zoom at his trial and did not receive ineffective assistance of counsel. Because the Court recognized that a criminal defendant's constitutional rights may be implicated when critical stages of court proceedings are conducted remotely, the Court provided guidance in this opinion to trial courts that offer defendants virtual or partly virtual bench trials during the COVID-19 pandemic. View "Commonwealth v. Curran" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions entered upon his conditional guilty plea to the charges of possession of a firearm without a license and possession of a large capacity feeding device, holding that the superior court did not err in denying Defendant's motion to suppress.On appeal, Defendant argued that the officers that stopped him after a routine traffic stop and then conducted a pat frisk did not have reasonable suspicion that he might be armed and dangerous. The Supreme Judicial Court affirmed the order denying Defendant's motion to suppress, holding that the facts, when taken together, warranted a reasonably prudent person's belief that Defendant was armed and dangerous. View "Commonwealth v. Sweeting-Bailey" on Justia Law

The Supreme Judicial Court affirmed the order of the superior court judge dismissing Plaintiff's civil action against the Appeals Court alleging various claims relating to property situated at 44 Chestnut Street in Wakefield, holding that there was no error.Plaintiff brought this action against multiple defendants, including the Appeals Court, claiming violations of various federal rights pursuant to 42 U.S.C. 1983 and violations of Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12131 et seq. The superior court dismissed the claims against all defendants through a series of rulings. The Supreme Judicial Court affirmed, holding that Plaintiff's section 1983 claims were barred by sovereign immunity and that Plaintiff's ADA claims were barred by absolute judicial immunity. View "Bostwick v. 44 Chestnut Street, Wakefield, Mass." on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree, assault and battery by means of a dangerous weapon, and other offenses, holding that Defendant was not entitled to reversal of his convictions.After he entered his appeal, Defendant filed a motion for a new trial. The superior court declined to act on the motion, as the Supreme Court would be reviewing the record. In his trial appeal, Defendant raised thirteen claims of error, and in his motion for a new trial, Defendant raised a number of claims that were also made virtually identically in his direct appeal. The Supreme Judicial Court affirmed, holding that Defendant was not entitled to relief as to either either his allegations of error on appeal or his motion for a new trial. View "Commonwealth v. Andrade" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Defendant's motion to withdraw his guilty pleas to indictments charging robbery, assault and battery by means of a dangerous weapon, unlawful possession of a firearm, and possession with intent to distribute a controlled substance, holding that Defendant was not entitled to relief.After learning of Annie Dookhan's misconduct in falsifying drug test results at the William A. Hinton State Laboratory Institute, Defendant filed a motion to withdraw his guilty pleas. Defendant's drug conviction was subsequently vacated. The superior court then denied Defendant's motion to withdraw his guilty pleas with respect to the non-drug-related charges. The superior court judge denied the motion, and the appeals court affirmed. The Supreme Judicial Court affirmed, holding that where a plea agreement involved multiple charges, some drug-related and others not, the presumption of governmental misconduct applies only to the tainted drug convictions. View "Commonwealth v. Henry" on Justia Law

The Supreme Judicial Court held that the responses of the named sheriff's offices in this complaint and their respective houses of correction to the COVID-19 pandemic did not violate Federal and State constitutional minimum requirements.At issue in this case was whether three alleged failures by certain of the Commonwealth's county sheriffs in their responses to the COVID-19 pandemic, including a failure to implement adequate COVID-19 testing strategies by the thirteen named defendants, violated Federal and State constitutional requirements. The Supreme Judicial Court denied relief, holding that there was no Federal or State constitutional violation as a result of Defendants' failure to implement comprehensive routine screening testing for COVID-19, to reduce population levels in the houses of correction, or to make more available three-way video conferencing for the purpose of attorney-client communication. View "Committee for Public Counsel Services v. Barnstable County Sheriff's Office" on Justia Law

The Supreme Judicial Court held that the medical parole scheme set forth in the Medical Parole Act, Mass. Gen. Laws ch. 127, 119A, authorizing the Commissioner of Correction to grant medical parole to terminally ill or permanently incapacitated prisoners, while delegating to the parole board oversight of a medical parolee's compliance with the conditions of parole imposed, does not offend due process.Plaintiff, an inmate, filed a petition for medical parole after being diagnosed with terminal cancer. Plaintiff was subsequently released on medical parole but later arrested for violating the terms of his release. Plaintiff's parole was later revoked, and the Commissioner denied Plaintiff's second petition for medical parole. Plaintiff then sought release from custody, and a single justice denied the request. The Supreme Judicial Court answered reported questions regarding the Medical Parole Act by holding that the statutory and regulatory scheme concerning the revocation of medical parole does not violate a parolee's right to due process. View "Emma v. Massachusetts Parole Board" on Justia Law

The Supreme Judicial Court vacated and set aside the order of the superior court judge denying Defendant's motion to suppress the fruits of a search of Defendant's home, holding that the warrantless investigatory review of the video footage taken from use of a body-worn camera that was unrelated to the domestic disturbance call in this case was unconstitutional.As he responded to a call about a domestic disturbance at Defendant's home, a police officer, who was equipped with a body-worn camera, created a digital recording of the encounter. The video footage was later retrieved and reviewed in connection with an ongoing independent investigation of Defendant for firearms offenses. Defendant was indicted on firearms-related offenses and moved to suppress the video recording from the body-worn camera and the fruits of the search warrant. The motion judge denied the motion. The Supreme Judicial Court vacated the order denying the motion to suppress, holding that (1) the use of the body-worn camera within the home was not an unconstitutional search; but (2) the later warrantless investigatory review of the video footage violated Defendant's constitutional right to be protected from unreasonable searches. View "Commonwealth v. Yusuf" on Justia Law