Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
by
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

by
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

by
The Supreme Judicial Court affirmed the judgment of the superior court judge denying Plaintiffs' second request for a preliminary injunction, holding that there was no error.Plaintiffs, a class of inmates in Department of Correction (DOC) facilities, brought this complaint alleging that the conditions of their confinement during the COVID-19 pandemic constituted cruel and unusual punishment under the Eighth Amendment and seeking to enjoin the DOC to use various measures to reduce the incarcerated population. After the class was certified Plaintiffs filed a second emergency motion for a preliminary injunction seeking an immediate reduction in the incarcerated population. The motion judge denied Plaintiffs' second motion for preliminary relief. The Supreme Judicial Court affirmed, holding that Plaintiffs were unlikely to prevail on their Eighth Amendment claim, and therefore, the superior court did not err in denying their second motion for preliminary relief. View "Foster v. Commissioner of Correction" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of the superior court denying Petitioner's petition for relief pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err in denying relief.Petitioner, who was awaiting trial on two counts of murder in the first degree and related firearm offenses, brought this action challenging the trial court's grant of the Commonwealth's motion for a protective order prohibiting defense counsel from providing Petitioner with copies of certain discovery materials. In his petition, Petitioner argued that the order would violate his constitutional right to prepare his defense. The single justice denied the petition without holding a hearing. The Supreme Judicial Court affirmed, holding that Petitioner failed to establish that the remedy of direct appeal would be inadequate in his case. View "Torres v. Commonwealth" on Justia Law

by
The Supreme Judicial Court affirmed the judgment of a single justice denying Plaintiff's complaint seeking a broad range of declaratory and injunctive relief, relief in the nature of mandamus, and the exercise of the Supreme Court's extraordinary power of general superintendence pursuant to Mass. Gen. Laws ch. 211, 3, holding that there was no error.This complaint stemmed from the district court's decision to nol pros several cases against individuals arrested at a "Straight Pride Parade" in Boston in 2019 and at a rally that followed. In his complaint, Plaintiff alleged that he was a victim of the disorderly conduct at the parade and rally because the charged individuals prevented him from marching or speaking in a way that interfered with his First Amendment rights. The single justice denied relief. The Supreme Judicial Court affirmed, holding that the single justice properly denied all relief on the complaint that was before her. View "Del Gallo v. District Attorney for the Suffolk District" on Justia Law

by
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

by
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

by
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

by
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

by
The Supreme Judicial Court held that the Commissioner of Correction's exercise of the "commissioner's certification" provision in Mass. Gen. Laws ch. 18(a) to retain K.J. at Bridgewater State Hospital violated article 30 of the Massachusetts Declaration of Rights.K.J., an adult man who faced criminal charges in the district court and the superior court, was committed involuntarily to Bridgewater. The commitment was subsequently extended. This appeal concerned the medical director of Bridgewater's most recent petition to have K.J. again recommitted for one year under section 18(a). The judge found that K.J. did not require strict custody and therefore, as required by section 18(a), issued an order committing K.J. to a lower security Department of Mental Health (DMH) facility. Despite that order, the Commissioner exercised the "commissioner's certification" provision in section 18(a) to retain K.J. at Bridgewater. The Supreme Judicial Court ordered that K.J. be transferred to a DMH facility, holding (1) the commissioner's certification provision of section 18(a) violates article 30; and (2) the remainder of section 18(a) is capable of separation. View "K.J. v. Superintendent of Bridgewater State Hospital" on Justia Law