Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of extreme atrocity or cruelty and felony-murder and related crimes and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E, holding that there was no reason to reverse the convictions or to reduce the degree of guilt. Specifically, the Court held (1) Defendant was not deprived of his constitutional right to a competent interpreter to interpret the trial proceeding into his native language; (2) despite Defendant's arguments to the contrary, trial counsel provided effective assistance; (3) there was no error in the jury instructions as to joint venture liability, the merger doctrine, and the duty to find the highest crime proved beyond a reasonable doubt; (4) the trial judge did not abuse his discretion in making certain rulings concerning the conduct of the trial; and (5) there was no reason to order a new trial or to reduce the degree of guilt. View "Commonwealth v. Lee" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on a theory of felony-murder and the denial of his motion for a new trial and declined to grant relief under Mass. Gen. Laws ch. 278, 33E, holding that there was no reason to order a new trial or to reduce the verdict of murder in the first degree. On appeal, Defendant argued that a new trial was necessary because his trial counsel provided ineffective assistance. The Supreme Judicial Court affirmed Defendant's convictions and the denial of his motion for a new trial and declined to reduce the verdict under Mass. Gen. Laws ch. 278, 33E, holding that Defendant's counsel did not provide ineffective assistance and that there was no reason to order a new trial or to reduce the verdict of murder in the first degree. View "Commonwealth v. Colon" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of possession of heroin with intent to distribute, reversed the denial of Defendant's motion for a new trial on the Mass. Gen. Laws ch. 94C, 32J (32J) charge, and vacated the conviction of a violation of section 32J, holding that counsel was ineffective in failing to challenge the sufficiency of the evidence regarding an essential element under section 32J. Defendant was convicted of possession of heroin with intent to distribute and with committing the crime within 100 feet of a public park, in violation of section 32J. The Supreme Judicial Court reversed in part, holding (1) the trial court did not err in denying Defendant's motion to suppress; (2) with respect to the "public park or playground" provision of section 32J, the intent to commit the underlying drug crime is sufficient, without additional proof of knowledge of park or playground boundaries required; (3) whether an area of land is a public park under section 32J is a question of fact properly left to the fact-finder; and (4) trial counsel was ineffective for failing to raise the variance between the park named in the indictment and the evidence presented at trial. View "Commonwealth v. Matta" on Justia Law

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The Supreme Judicial Court dismissed the Commonwealth's appeal from the trial court's allowance of Defendant's motion filed under Mass. R. Crim. P. 25(a), holding that the trial judge erred in reserving decision on Defendant's Rule 25(a) motion and that the error violated Defendant's right to due process and permeated the remainder of the trial. Defendant was charged with murder in the first degree. At the close of the Commonwealth's case Defendant moved for a required finding of not guilty pursuant to Rule 25(a). The judge reserved decision and submitted the case to the jury. The jury found Defendant guilty of murder in the second degree. Defendant subsequently renewed his motion under Rule 25(a). The judge allowed the motion, nunc pro tunc, to the close of the Commonwealth's case. The Commonwealth petitioned for relief under Mass. Gen. Laws ch. 211, 3. The Supreme Judicial Court denied relief, holding (1) in allowing the motion for a required finding nunc pro tunc after the jury returned their verdict the judge deprived the Commonwealth of its right to appeal from a postverdict acquittal; but (2) because the initial error in reserving decision on the motion implicated Defendant's constitutional rights and infected the remainder of the trial, the Commonwealth could not appeal. View "Commonwealth v. Yasin" on Justia Law

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The Supreme Court vacated the order of the superior court judge allowing Defendant's motion to suppress all evidence related to an illegal seizure on the ground that the stop of his motor vehicle was not reasonable, holding that the police officer's stop of Defendant's motor vehicle for failing to drive entirely within a marked traffic lane was reasonable and, therefore, constitutional. Defendant was charged with a marked lanes violation in accordance with Mass. Gen. Laws. ch. 89, 4A and operating a motor vehicle while under the influence of intoxicating liquor. The judge allowed Defendant's motion to suppress, ruling that Defendant had not violated section 4A, and therefore, the stop of his motor vehicle was not reasonable. The Supreme Court vacated the judge's order, holding that Defendant violated section 4A when he crossed the right-side fog line one time for two or three seconds, and therefore, the ensuing traffic stop was reasonable. View "Commonwealth v. Larose" on Justia Law

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The Supreme Judicial Court vacated Defendant's conviction of involuntary manslaughter but affirmed Defendant's conviction of distribution of heroin, holding that the Commonwealth did not introduce evidence showing that Defendant knew or should have known that his conduct created a high degree of likelihood of substantial harm. Defendant had provided a college student with the heroin that caused the student's death. Defendant was convicted of involuntary manslaughter and distribution of heroin. Defendant appealed, arguing, inter alia, that the judge erred in denying his request to instruct the jury on the lesser included offense of possession of heroin for personal use because the student asked Defendant to purchase heroin for him and Defendant did not profit from the sale. The Supreme Judicial Court affirmed in part and vacated in part, holding (1) under the circumstances of this case, the judge did not err in denying Defendant's request for a lesser included jury instruction on simple possession; but (2) there was insufficient evidence for a reasonable jury to conclude that Defendant's conduct created a high degree of likelihood that the student would suffer substantial harm for his use of the heroin. View "Commonwealth v. Carrillo" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to grant a new trial or to reduce or set aside the verdict, holding that none of Defendant's allegations of error warranted reversal. On appeal, Defendant argued that the trial judge erred in instructing the jury and in admitting conversations recorded while Defendant was in pretrial detention. The Supreme Judicial Court affirmed, holding (1) the jury instructions did not prejudice Defendant; and (2) there was no violation of Defendant's constitutional rights in the admission of the recorded conversations. View "Commonwealth v. Odgren" on Justia Law

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The Supreme Judicial Court reversed in part the superior court's order denying in part and affirming in part Defendant's motions to suppress, holding that the superior court erred in denying Defendant's motions to suppress evidence obtained from a search of his cellular telephone and the cell site location information (CSLI). Police officers asked a Spanish-speaking officer untrained in interpretation to translate Miranda warnings and an interrogation into Spanish. Defendant subsequently waived his rights and spoke with police. Defendant also gave the officers permission to search his telephone. Officers used that information to obtain a warrant for the CSLI on Defendant's phone. Defendant filed several motions to suppress. The superior court allowed the motions with respect to the custodial statements but denied them in all other respects. The Supreme Court reversed in part, holding (1) the identifications did not require suppression; (2) the translation of the Miranda warnings into Spanish was inadequate to apprise Defendant of his rights; (3) because the search of Defendant's cellular telephone arose from the statements he made following the incomplete Miranda warnings, the evidence obtained as a result must be suppressed; and (4) the affidavit in support of the search warrant for the CSLI did not establish probable cause to access the CLSI for Defendant's device. View "Commonwealth v. Vasquez" on Justia Law

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The Supreme Judicial Court affirmed in part and reversed in part the superior court's denial of Defendant's motion seeking a refund of fees associated with his vacated convictions, holding that due process principles required a refund of a drug analysis fee but did not require a refund of other fees. Defendant pleaded guilty to two counts of distribution of cocaine. Defendant later sought a new trial due to the misconduct of Sonja Farak, a chemist who analyzed the substances seized in Defendant's case. The indictments were subsequently dismissed with prejudice on the Commonwealth's motion. Thereafter, Defendant filed a motion seeking a refund of fees associated with the vacated convictions, including the drug analysis fee and fees Defendant incurrent on an account he was obligated to maintain while he was incarcerated. The superior court denied the motion. The Supreme Judicial Court reversed the order to the extent that the order denied a refund of the drug analysis fee and affirmed the order in all other respects, holding that Defendant was entitled to a refund of a drug analysis fee but that neither statute nor due process required that fees Defendant incurred on his inmate account be refunded. View "Commonwealth v. Watt" on Justia Law

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The Supreme Judicial Court vacated the jury's verdict convicting Defendant of murder in the first degree, holding that the motion judge abused his discretion in denying Defendant's motion for a new trial because defense counsel's failure to request a voluntary manslaughter instruction created a substantial likelihood of a miscarriage of justice. In his motion for a new trial, Defendant contended that his trial counsel's performance was deficient because counsel failed to request a voluntary manslaughter jury instruction based on reasonable provocation. The Supreme Judicial Court remanded the matter to the superior court for a new trial, holding that the motion judge abused his discretion in determining that trial counsel's decision not to request a voluntary manslaughter instruction was a reasonable tactical choice. View "Commonwealth v. Rhodes" on Justia Law