Justia Massachusetts Supreme Court Opinion Summaries

In 2020, a police officer applied for a criminal complaint in the District Court, alleging that the defendant possessed a loaded firearm while intoxicated. A clerk-magistrate denied the application, finding no probable cause that the defendant had a firearm under his control inside a motor vehicle. No review of this decision was sought. Over two years later, the same officer filed a new application for the same offense with the same facts, and a different clerk-magistrate found probable cause and issued the complaint.The defendant filed a petition for extraordinary relief, arguing that the issuance of the complaint was barred by collateral estoppel and that the delay violated his due process rights. A single justice of the county court reserved and reported the petition to the full court.The Supreme Judicial Court of Massachusetts held that the principles of collateral estoppel did not bar the issuance of the complaint because the initial denial was not a final judgment. The court noted that a District Court determination of no probable cause is not conclusive and does not bar a subsequent indictment for the same offense. The court also found no due process violation, as the defendant did not have a constitutionally protected interest in the finality of a show cause determination, and the delay did not cause severe prejudice to the defendant's ability to mount a defense. The court remanded the case to the county court for entry of a judgment denying the defendant's petition for extraordinary relief. View "Cabrera v. Commonwealth" on Justia Law

The case involves the admissibility of location data obtained from a GPS device imposed on the defendant as a condition of pretrial release. The defendant was involved in a domestic violence incident on December 26, 2019, where he threatened his ex-wife, C.P., and discharged a firearm. He was later apprehended in July 2020 and released on bail with conditions, including GPS monitoring. In August 2020, following a shooting incident, police retrieved the defendant's GPS data to determine his proximity to the crime scene.The Superior Court denied the defendant's motion to suppress the GPS evidence, and he entered a conditional guilty plea, reserving the right to appeal the suppression ruling. The case was transferred to the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court addressed two main issues: whether the initial imposition of GPS monitoring was an unreasonable search under Article 14 of the Massachusetts Declaration of Rights, and whether the subsequent retrieval and review of the defendant's GPS data constituted an unreasonable search.The court held that the initial imposition of GPS monitoring was a search but was reasonable under Article 14 due to the legitimate governmental interests in protecting the alleged victims and ensuring compliance with the conditions of pretrial release. The court found that the defendant's privacy expectations were outweighed by these interests.Regarding the retrieval and review of the GPS data, the court concluded that it did not constitute a search under Article 14. The defendant did not have a reasonable expectation of privacy in the specific location data retrieved, as it was limited in scope and duration, and the defendant was aware that his movements could be monitored for compliance with pretrial conditions.The Supreme Judicial Court affirmed the lower court's order denying the motion to suppress. View "Commonwealth v. Govan" on Justia Law

A child was temporarily removed from her parents' care shortly after birth and placed in the custody of the Department of Children and Families (DCF) due to concerns about domestic violence. DCF sought to vaccinate her according to an age-based immunization schedule, but her parents, practicing Rastafarians, objected on religious grounds. A Juvenile Court judge allowed DCF to facilitate vaccinations for the child. The parents sought to stop future vaccinations, arguing that vaccinating their child over their religious objections violated their constitutional rights.The Juvenile Court judge found that the parents' religious beliefs were outweighed by the child's best interests and allowed DCF to vaccinate the child. The parents petitioned the Appeals Court for interlocutory relief, which was denied. The parents then appealed to the Appeals Court panel, and the child sought direct appellate review in the Supreme Judicial Court, which was granted.The Supreme Judicial Court of Massachusetts held that the order allowing the child to be vaccinated violated the parents' constitutional rights. The court concluded that the parents' sincerely held religious beliefs were substantially burdened by DCF's vaccination efforts. The court applied the State constitutional protections afforded to parents exercising their free exercise rights and determined that DCF failed to demonstrate that exempting the child from vaccinations would substantially hinder the fulfillment of DCF's interests in promoting child health. The court noted the Commonwealth's allowance of religious exemptions from vaccination requirements for parents who have not lost custody and DCF's inconsistent exercise of its authority to order vaccinations for children in its care. The order allowing the joint motion by DCF and the child to facilitate the vaccination of the child was reversed. View "Care and Protection of Eve" on Justia Law

Two detectives from the Lowell police department, while investigating a home invasion in Lowell, Massachusetts, crossed into Nashua, New Hampshire, to speak with the defendant. During the conversation, one detective suspected the defendant was deleting data from his cell phone and seized it without a warrant. The detectives then brought the phone back to Massachusetts and obtained a warrant to search it.In the Superior Court, the defendant moved to suppress the evidence obtained from the cell phone, arguing that the seizure was unlawful. The motion judge allowed the motion, finding that the Lowell detectives had no authority to seize the phone in New Hampshire. The Commonwealth sought an interlocutory appeal, which was allowed by a single justice of the Supreme Judicial Court for the county of Suffolk. The case was then transferred to the Supreme Judicial Court on its own initiative.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the Lowell detective did not have extraterritorial authority to seize the cell phone in New Hampshire. The court found that no statutory or common law authority permitted the warrantless seizure in these circumstances. The court also rejected the Commonwealth's argument that the evidence would have been inevitably discovered, as this theory was not sufficiently supported by the record. The court held that suppression of the evidence was the appropriate remedy to deter police misconduct and preserve judicial integrity. The order allowing the motion to suppress was affirmed. View "Commonwealth v. McCarthy" on Justia Law

A juvenile was found delinquent on firearm charges and guilty on a youthful offender indictment for one of the offenses. At the trial, the juvenile was nineteen years old, and the Commonwealth called his mother to testify about events that occurred when he was seventeen. The juvenile argued that the parent-child witness disqualification statute, which prohibits testimony by a parent against their minor child, should have precluded his mother's testimony even though he was no longer a minor at the time of trial. He also claimed that the trial judge made several errors in admitting other evidence and that his sentence was unlawful and unconstitutional.The juvenile was charged in a delinquency complaint with possession of a firearm without a firearm identification card, unlawful possession of a large capacity feeding device, and improper storage of a firearm. He was subsequently indicted as a youthful offender for the large capacity feeding device charge. The juvenile filed a motion to prevent the Commonwealth from calling his mother as a witness, invoking the parent-child witness disqualification statute. The motion judge denied the motion, reasoning that the statute applied only to testimony against a minor child, and the juvenile was no longer a minor.The Supreme Judicial Court of Massachusetts reviewed the case and agreed with the trial judge's interpretation that the statutory prohibition of testimony by a parent against their minor child does not apply once the child has reached the age of eighteen. The court found no prejudicial error in the admission of other evidence, although it concluded that the judge should not have admitted a detective's testimony that a firearm depicted in still images was "identical" to the firearm admitted in evidence, nor two hearsay statements. Regarding the juvenile's sentence, the court agreed that the judge erred in not issuing written findings explaining the sentence but concluded that this error did not prejudice the juvenile. The court affirmed the juvenile's delinquency and youthful offender adjudications and declined to vacate his sentence. View "Commonwealth v. Rajiv R." on Justia Law

A Cambridge police officer observed a black Mazda sedan with an unilluminated rear license plate and initiated a traffic stop. The driver, Natnael Zemene, and two passengers were removed from the vehicle for an inventory search, which revealed a bottle of tequila and a box of ammunition. During a subsequent pat frisk, a firearm was found under Zemene's foot. Zemene admitted ownership of the firearm and was arrested.Zemene was charged with possession of ammunition without a license, carrying a firearm without a license, carrying a loaded firearm without a license, unlicensed operation of a motor vehicle, and two civil motor vehicle infractions. He was found guilty of carrying a firearm without a license but not guilty of the other charges. The trial judge denied his motion for a required finding of not guilty and sentenced him to eighteen months in a house of correction. Zemene's post-trial motions were denied, and his sentence was stayed pending appeal.The Supreme Judicial Court of Massachusetts reviewed the case. Zemene argued that retrial on the charge of carrying a firearm without a license would violate the double jeopardy clause. The court held that the relevant legal change occurred with its decision in Commonwealth v. Guardado, not the U.S. Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen. Therefore, the double jeopardy clause did not bar retrial. The court affirmed the single justice's denial of Zemene's petition for relief. View "Zemene v. Commonwealth" on Justia Law

The defendant, a New Hampshire resident, was arrested in Massachusetts on November 8, 2021, for operating a motor vehicle under the influence of alcohol following a collision. During a search of his vehicle, a handgun and ammunition were found. The defendant did not have a Massachusetts nonresident firearm license and was charged with unlawful possession of a firearm under G. L. c. 269, § 10 (a). He moved to dismiss the charge, arguing that the nonresident licensing scheme violated his Second Amendment rights, relying on the U.S. Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen.The District Court judge allowed the motion to dismiss, concluding that the nonresident licensing scheme was unconstitutional as applied to the defendant. The judge found that the scheme violated the Second Amendment by imposing discretionary licensing requirements on nonresidents. The Commonwealth appealed, and the Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the Commonwealth's prior nonresident firearm licensing scheme, which allowed the State police colonel discretion to issue or deny licenses, violated the Second Amendment under the Bruen decision. The court noted that such discretionary "may issue" regimes are presumptively invalid and not supported by historical tradition. The court also found that the impermissible portions of the statute could not be severed from the remainder, rendering the entire scheme unconstitutional. Consequently, the court affirmed the dismissal of the charge against the defendant. View "Commonwealth v. Donnell" on Justia Law

The defendant, a New Hampshire resident, was involved in a vehicle accident in Massachusetts and was found in possession of an unlicensed firearm. He was charged with unlawful possession of a firearm and ammunition. The defendant filed a motion to dismiss, arguing that the Commonwealth's nonresident firearm licensing scheme violated his Second Amendment rights in light of the Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen. The motion judge allowed the motion to dismiss, and the Commonwealth appealed.The Supreme Judicial Court of Massachusetts reviewed the case. The court first determined that the defendant lacked standing to bring an as-applied challenge to the Commonwealth's nonresident firearm licensing scheme because he had not applied for and been denied a license under that scheme. The court then considered the merits of a facial challenge to the scheme.The court held that the Commonwealth's nonresident firearm licensing scheme is consistent with the Second Amendment. The scheme's purpose is to restrict access to firearms by demonstrably dangerous persons, which is consistent with the nation's historical tradition of firearm regulation. The court also found that the scheme's "shall issue" licensing regime, which requires nonresidents to meet specific criteria to obtain a license, is analogous to historical regulations such as surety and going armed laws.Additionally, the court held that the scheme does not violate the Fourteenth Amendment rights to travel and to equal protection. The differences in the treatment of resident and nonresident license applicants, such as license duration and processing times, are rationally related to the legitimate state interest of ensuring public safety.The Supreme Judicial Court reversed the motion judge's order allowing the defendant's motion to dismiss, upholding the constitutionality of the Commonwealth's nonresident firearm licensing scheme. View "Commonwealth v. Marquis" on Justia Law

The defendant, a police captain in the West Springfield police department, was found guilty of obtaining an unwarranted privilege with fraudulent intent by using over $1,000 from the police department's evidence room to pay his home mortgage. The defendant was sentenced to a one-year term of probation. He appealed his conviction on the grounds that the statutes under which he was convicted were unconstitutionally vague and that the evidence was insufficient to prove he acted with fraudulent intent or that the unwarranted privilege had a fair market value of over $1,000 in any twelve-month period.The Superior Court denied the defendant's pretrial motion to dismiss the indictment. After a jury-waived trial, the trial judge found the defendant guilty and denied his motion for a required finding of not guilty. The defendant then appealed to the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court affirmed the conviction, holding that the statutes in question were not unconstitutionally vague. The court found that the terms "unwarranted privilege" and "fraudulent intent" provided sufficient notice of prohibited conduct to a person of reasonable intelligence. The court also concluded that the evidence was sufficient to prove the defendant acted with fraudulent intent, as he had secreted money from the evidence room to pay his mortgage and made false statements to investigators. Additionally, the court determined that the fair market value of the unwarranted privilege exceeded $1,000, based on the face value of the money taken from the evidence room. View "Commonwealth v. Spaulding" on Justia Law

In 2018, the victim ended a five-year relationship with the defendant, who continued to send her text messages and occasionally parked near her home despite her efforts to avoid him. Two years later, the defendant sent the victim two text messages expressing anger and hurt. The next day, after an encounter at a fundraiser, the defendant sent another text message threatening to punch the victim.The defendant was convicted of violating the threatening to commit a crime statute in the New Bedford Division of the District Court Department. The Appeals Court affirmed the conviction, but the Supreme Judicial Court granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the jury was not instructed to find that the defendant acted with the required mens rea, as established by the U.S. Supreme Court in Counterman v. Colorado. The Court held that the conviction violated the First Amendment because the jury was not instructed to find that the defendant consciously disregarded a substantial risk that his communication would be viewed as threatening violence. The Court also concluded that the threatening to commit a crime statute is not facially overbroad when construed to require proof of recklessness. The Court vacated the defendant's conviction and remanded the case for a new trial, allowing the Commonwealth to retry the defendant with proper jury instructions. View "Commonwealth v. Cruz" on Justia Law