Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court reversed the order of the superior court concluding that the Commonwealth's exercise of its statutory right to demand a jury trial violated Petitioner's substantive due process rights and allowing Petitioner's motion for a bench trial, holding that the judge erred in concluding that Petitioner's substantive due process rights were violated.A jury found Petitioner to be a sexually dangerous person, and Petitioner was committed to the Massachusetts Treatment Center. Petitioner later filed a motion pursuant to Mass. Gen. Laws ch. 123A, 9 for discharge from civil commitment as a sexually dangerous person. A jury trial in 2018 resulted in a mistrial, and the matter was rescheduled for retrial in 2020. The trial, however, was continued indefinitely because of the COVID-19 pandemic and the suspension of jury trials in the state. A superior court judge granted Petitioner's motion to proceed with a bench trial, concluding that it was unconstitutional for the Commonwealth to exercise its right to demand a jury trial. The Commonwealth appealed. The Supreme Judicial Court reversed, holding that continuing commitment after a single mistrial where Petitioner was previously found to be sexually dangerous did not violate Petitioner's due process rights and did not require that Petitioner be given the opportunity to seek release pending trial. View "In re LeSage" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of deliberate premeditation and declined relief pursuant to Mass. Gen. Laws ch. 278, 33E, holding that there was no reason to order a new trial, reduce the verdict, or grant any other relief.Specifically, the Supreme Judicial Court held (1) the trial judge did not err in declining to instruct the jury on voluntary manslaughter; (2) the trial judge did not erred in allowing a Boston police detective to testify about the contents of a certain record of the United States Customs and Border Protection agency that he saw on a computer screen at Logan Airport, but the error was not prejudicial; (3) the trial judge's instruction to the jury in response to Defendant's closing argument was not prejudicial; and (4) the prosecutor's remarks during closing arguments did not rise to the level of prejudicial error. View "Commonwealth v. Brea" on Justia Law

The Supreme Judicial Court Mass. Gen. Laws ch. 233, 20, Fourth - which applies to the testimony of a parent of minor child against the other in criminal, delinquency, and youthful offender proceedings where the victim is not a family member and does not reside in the household - does not disqualify parents from being called as witnesses for the defense to testify at an evidentiary hearing for a motion to suppress.Juvenile was indicted as a youthful offender on the charge of carrying a firearm without a license. Before trial, Juvenile moved to suppress certain statements he made to the police and sought to call his mother to testify at the evidentiary hearing. The Commonwealth sought to prohibit the juvenile's mother from testifying based on section 20, Fourth. The judge denied the motion. The Supreme Judicial Court affirmed, holding (1) section 20, Fourth prevents the prosecution from calling the child's parents to testify for the Commonwealth in youthful offender proceedings where the victim is not a family member and does not reside in the household; but (2) section 20, Fourth allows the child to call his or her parents as witnesses for the defense and then the Commonwealth to cross-examine them. View "Commonwealth v. Vigiani" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for trafficking of persons for sexual servitude and unlawful possession of marijuana, holding that the superior court judge did not err denying Defendant's motion to suppress and that there were no errors necessitating a new trial.Specifically, the Supreme Judicial Court held (1) the motion judge did not err in denying Defendant's motion to suppress evidence obtained from sex cell phones; (2) the judge did not commit reversible error in allowing the Commonwealth's motion in limine seeking to introduce certain text messages as statements by a coventurer, andthe judge's failure to provide a limiting instruction was error but did not prejudice Defendant; (3) the judge did not abuse her discretion in permitting the introduction of prior bad acts; and (4) there was no other prejudicial error in the proceedings. View "Commonwealth v. Lowery" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of assault and battery and strangulation, holding that admitting the victim's statements did not violate Defendant's right to confrontation under the Sixth Amendment to the United States Constitution and article 12 of the Massachusetts Declaration of Rights.The victim did not testify at trial. Instead, a recording of the victim's 911 call and the responding officers' recounting of the victim's statements were admitted. The Appeals Court reversed Defendant's convictions on the grounds that his confrontation rights were violated. On appeal, the Supreme Judicial Court affirmed Defendant's convictions, holding (1) because most of the admitted statements were not made with the primary purpose of creating a substitute for trial testimony they were non testimonial and did not violate Defendant's confrontation rights; and (2) to the extent that the victim's statements were testimonial, the only such statement was duplicative of other evidence, and its admission was harmless beyond a reasonable doubt. View "Commonwealth v. Rand" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the court denying Plaintiff's petition for relief after she was suspended without pay from her position as an assistant clerk-magistrate in the superior court following her indictment on felony charges, holding that there was no error or abuse of discretion in the denial of relief.In her petition, Plaintiff argued, among other things, that the executive office of the trial court exceeded its authority by acting pursuant to a provision of its personnel manual mandating suspension without pay of employees charged with felonies. The Supreme Judicial Court affirmed, holding (1) Plaintiff's suspension without pay upon the issuance of a federal felony indictment was consistent with and mandated by the terms of the personnel manual, the promulgation of which constituted a permissible exercise of the Court Administrator's authority; (2) the single justice did not err in finding that the trial court's procedures satisfied due process; and (3) Plaintiff was not entitled to relief on her equal protection claims. View "Moore v. Executive Office of the Trial Court" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree on the theory of felony-murder, unlawful possession of a firearm, and attempted armed robbery, holding that there was no error.Specifically, the Supreme Judicial Court held (1) counsel's failure to file a motion to suppress Defendant's text messages was not ineffective assistance of counsel because probable cause was established; (2) counsel was not ineffective for failing to exclude cell site location information; (3) Defendant was not was prejudiced by defense counsel's failure to object to in-court and out-of-court identifications made by an eyewitness; and (4) there was no other basis to set aside or reduce the verdict of murder in the first degree or to order a new trial under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Louis" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, on a theory of felony order, with aggravated rape as the predicate felony, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Judicial Court held (1) there was sufficient evidence to prove that the homicide and the aggravated rape were parts of one continuous event; (2) if there was any error in the prosecutor's closing argument, Defendant was not prejudiced by it; (3) there was no error in the judge's Tuey-Rodriguez charge to the jury; (4) the judge's response to a jury question about the permissibility of inferences from a lack of evidence did not violate Defendant's right to due process; and (5) there was no reason to reduce the verdict or to order a new trial under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Witkowski" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court allowing Defendant's motion to suppress all of the statements he made after having invoked his right to counsel, holding that the trial judge did not err in granting the motion to suppress.Defendant was arrested on charges of murder in the first degree and possession of a firearm without a license. Although Defendant first agreed to waive his Miranda rights and speak with police in an interrogation room, twenty minutes after the interview began Defendant requested to speak with an attorney. Forty-five minutes later, Defendant again waived his Miranda rights and agreed with speak with the police. Defendant was subsequently interviewed for about one hour. Thereafter, Defendant moved to suppress all of the statements he made after having invoked his right to counsel. The superior court judge allowed the motion to suppress, concluding that it had not been established beyond a reasonable doubt that Defendant reinitiated the interview and knowingly, voluntarily, and intelligently waived his right to counsel. The Supreme Judicial Court affirmed, holding that the trial judge did not err. View "Commonwealth v. Gonzalez" on Justia Law

The Supreme Judicial Court held that social workers, and their approving supervisors, in the Department of Children and Families who attest to facts in sworn affidavits as part of care and protection proceedings commenced by the Department in the juvenile court pursuant to Mass. Gen. Laws. ch. 119, 24 are entitled to absolute immunity in these circumstances.Plaintiff brought an action pursuant to 42 U.S.C. 1983 against a social worker with the Department, alleging that the social worker intentionally misrepresented facts in a sworn affidavit filed in support of a care and protection petition in the juvenile court. Plaintiff further alleged that the social worker's area supervisor (together, with the social worker, Defendants) was liable because she had approved the social worker's actions. Defendants filed a motion for judgment on the pleadings, arguing that they were entitled to absolute immunity. A superior court judge allowed the motion. The Supreme Judicial Court affirmed, holding that Defendants were entitled to absolute immunity under the circumstances of this case. View "C.M. v. Commissioner of Department of Children & Families" on Justia Law