Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Judicial Court remanded this matter to the county court for entry of a judgment allowing Defendant's petition pursuant to Mass. Gen. Laws ch. 211, 3 and ordering that the superior court judge's order hospitalizing Defendant under Mass. Gen. Laws ch. 123, 16(a) be vacated, holding that Defendant's substantive due process rights were violated.A grand jury returned a twelve-count indictment charging Defendant with two counts of armed carjacking and multiple related charges. After a jury-waived trial, Defendant was found not criminally responsible by reason of mental illness. Thereafter, the judge granted the Commonwealth's motion to hospitalize Defendant for evaluation pursuant to section 16(a) for forty days. Defendant filed a petition pursuant to section 3 requesting relief from confinement. A single justice denied the petition. The Supreme Judicial Court remanded the matter, holding that there was no constitutionally adequate justification to temporarily commit Defendant under section 16(a). View "Garcia v. Commonwealth" on Justia Law

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The Supreme Judicial Court held that the ministerial exception did not apply to Plaintiff, an associate professor of social work at a private Christian liberal arts college, and therefore, the superior court judge did not err in dismissing on summary judgment Gordon College's affirmative defense of the ministerial exception in this retaliation complaint.The ministerial exception prohibits government interference with employment relationships between religious institutions and their ministerial employees. Plaintiff, a tenured associate professor of social work at Gordon, alleged that Defendants - Gordon and its president and provost (collectively, Gordon) - unlawfully retaliated against her for her opposition to Gordon's policies and practices regarding LGBTQ+ individuals. The parties cross-moved for summary judgment on the question of whether the ministerial exception barred Plaintiff's claims. The superior court allowed Plaintiff's motion but denied Gordon's, concluding that Gordon was a religious institution but that Plaintiff was not a ministerial employee. The Supreme Judicial Court affirmed, holding that the superior court judge did not err in dismissing the affirmative defense of the ministerial exception. View "DeWeese-Boyd v. Gordon College" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions three counts of murder in the first degree and concluded that Defendant was not entitled to relief under Mass. Gen. Laws ch. 278, 33E, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Judicial Court held (1) the trial judge erred by giving a charge in accordance with Commonwealth v. Rodriguez, 364 Mass. 87 (1973), and Commonwealth v. Tuey, 8 Cush. 1, 2-3, to an individual juror after the jury had been polled, but the error was not prejudicial; (2) some the trial judge's rulings admitting prior bad acts evidence were in error, but the errors were not prejudicial; (3) the judge did not abuse his discretion in admitting coventurer statements; (4) certain remarks made by the prosecutor in opening and closing arguments were in error, but the error was not prejudicial; (5) the trial judge did not err by denying Defendant's motion to suppress; and (6) this Court declines to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or direct the entry of verdicts of a lesser degree of guilt. View "Commonwealth v. Chalue" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction for murder in the first degree with deliberate premeditation, holding that there was no reversible error in the proceedings below and no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce or set aside the verdict.Specifically, the Supreme Judicial Court held that the trial judge did not commit prejudicial error in (1) allowing the Commonwealth's peremptory challenges of two prospective jurors over Defendant's objections pursuant to Batson v. Kentucky, 476 U.S. 79 (1986), and Commonwealth v. Soares, 377 Mass. 461 (1979); (2) admitting a graphic autopsy photograph; and (3) allowing rebuttal testimony about overheard telephone statements of a Commonwealth witness imparting that she altered her testimony upon receipt of death threats and denying Defendant's request to conduct consequent voir dire of that witness. View "Commonwealth v. Jackson" on Justia Law

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The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition filed pursuant to Mass. Gen. Laws ch. 211, 3 seeking relief from a superior court judge's order denying his motion to continue the third day of an evidentiary suppression hearing, holding that the single justice did not err or abuse his discretion.At issue before the single justice was whether the trial judge's directive to Petitioner to make a choice whether to appear for an evidentiary hearing in person or via video conference was sufficiently important and extraordinary as to warrant the exercise of the Supreme Judicial Court's extraordinary power pursuant to Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court held that the single justice did not err or abuse his discretion in denying Petitioner's petition. View "Malary v. Commonwealth" on Justia Law

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The Supreme Judicial Court vacated the judgments entered against Defendant in this criminal case, holding that the trial judge abused his discretion in excusing a juror who claimed to be unable to begin deliberations anew after the discharge of another juror.A jury convicted Defendant of murder in the first first degree on a theory of felony murder, as well as assault and battery by means of a dangerous weapon causing serious bodily injury and possession of a firearm. On appeal, Defendant argued that the motion judge erred in denying his motion to suppress and that the trial judge erred in excusing a juror. The Supreme Judicial Court vacated the judgments entered against Defendant, holding (1) the trial court did not err in denying Defendant's motion to suppress; but (2) the trial court's discharge of the juror in question was error, and the error was prejudicial to Defendant. View "Commonwealth v. Williams" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree by deliberate premeditation and of unlawful possession of a firearm, holding that a new trial was not required because there was no error and that there was no reason for the Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict of murder in the first degree.Specifically, the Supreme Judicial Court held (1) the trial judge did not err by declining to give a requested instruction on self-defense; (2) the trial judge did not abuse his discretion by allowing the prosecutor to introduce prior bad act evidence; (3) the prosecutor's remarks in her opening statement and closing argument did not create a substantial likelihood of a miscarriage of justice; (4) trial counsel provided constitutionally effective assistance; and (5) a new trial was not warranted based on purported newly discovered evidence. View "Commonwealth v. Teixeira" on Justia Law

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The Supreme Judicial Court vacated the trial judge's order allowing Defendant's motion to suppress evidence found on Defendant's cell phone and remanded the case to the superior court for further rulings regarding partial suppression, holding that there was probable cause to search Defendant's cell phone and that the search of the phone was not sufficiently particular because it lacked any temporal limit.When Defendant was arrested in connection with a fatal shooting police officers obtained a warrant to search Defendant's cell phone for evidence related to the crime. The judge allowed Defendant's motion to suppress the cell phone evidence, ruling that the warrant had issued without probable cause because it lacked a sufficient nexus between the murder and Defendant's cell phone and noting that the search was not limited in time. The Supreme Judicial Court vacated the suppression order, holding (1) there was probable cause to search Defendant's cell phone; and (2) because the record was silent with respect to the dates of the Commonwealth's proposed evidence, remand was required for a determination of whether the evidence would have fallen within a reasonable temporal limit. View "Commonwealth v. Snow" on Justia Law

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The Supreme Judicial Court affirmed the order of the superior court denying Defendant's motion for relief from a condition of probation, holding that imposition of the condition did not violate Defendant's rights under article 14 of the Massachusetts Declaration of Rights.Defendant pleaded guilty to multiple counts of possession and dissemination of child pornography and was sentenced to concurrent terms of incarceration, suspended subject to compliance with special conditions of probation. At issue was the condition requiring Defendant to allow the probation department to conduct random suspicionless searches of his electronic devices and other locations where child pornography might be stored. Before the Supreme Court, Defendant argued that this condition authorized unreasonable searches in violation of article 14. The Court upheld the condition, holding (1) on its face, the condition subjected Defendant to the continuing possibility of unreasonable searches throughout the term of his probation and was too broad; but (2) properly limited, imposition of the condition did not violate Defendant's rights under article 14. View "Commonwealth v. Feliz" on Justia Law

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The Supreme Judicial Court affirmed Defendant's convictions for murder in the first degree and related charges and the order denying Defendant's motion for a new trial, holding that the trial judge did not err in denying Defendant's request that the jury be instructed on withdrawal from a joint venture.Specifically, the Supreme Court held (1) Defendant was not entitled to an instruction on withdrawal from a joint venture; (2) Defendant was not deprived of the effective assistance of counsel when counsel did not request a supplemental jury instruction to further explain the Commonwealth's burden to prove that the killing occurred during the course of the underlying felony and when counsel did not object to a portion of the prosecutor's closing argument; and (3) this Court declines to exercise its authority under Mass. Gen. Laws ch. 278, § 33E to reduce the murder conviction to murder in the second degree. View "Commonwealth v. Tillis" on Justia Law