Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the order of the denying Defendant's motion to suppress evidence obtained after surveillance was conducted at Defendant's apartment building via a hidden video camera placed on a nearby public utility pole, holding that although the pole camera surveillance constituted a warrantless search under article 14 of the Massachusetts Declaration of Rights, it was nevertheless constitutional.Defendant was indicted on child pornography charges. After the surveillance at issue in this case took place but before the superior court decided Defendant's motion to suppress, Commonwealth v. Mora, 485 Mass. 360 (2020) was decided. In Mora, the Supreme Judicial Court decided that pole camera surveillance could, under certain circumstances, constitute a search requiring a warrant. After the motion to suppress in this case was decided, Defendant brought an interlocutory appeal. The Supreme Judicial Court affirmed the order denying Defendant's motion to suppress, holding (1) the pole camera surveillance constituted a search; but (2) probable cause existed to conduct the pole camera surveillance prior to the time the search began. View "Commonwealth v. Comenzo" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theories of deliberate premeditation and extreme atrocity or cruelty and assault and battery by means of a dangerous weapon, holding that there was no reversible error in the proceedings below.Defendant was sentenced on the murder conviction to a term of life in State prison, to be served after his sentence for assault and battery. On appeal, Defendant filed a motion for a new trial based on ineffective assistance of counsel. The trial judge denied the motion. The Supreme Judicial Court affirmed, holding that there was no reversible error in the trial proceedings and that there was no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce or set aside the verdict of murder in the first degree. View "Commonwealth v. Denson" on Justia Law

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