Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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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

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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

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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

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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

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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

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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

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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

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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

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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

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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