Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant's convictions of assault and battery and strangulation, holding that admitting the victim's statements did not violate Defendant's right to confrontation under the Sixth Amendment to the United States Constitution and article 12 of the Massachusetts Declaration of Rights.The victim did not testify at trial. Instead, a recording of the victim's 911 call and the responding officers' recounting of the victim's statements were admitted. The Appeals Court reversed Defendant's convictions on the grounds that his confrontation rights were violated. On appeal, the Supreme Judicial Court affirmed Defendant's convictions, holding (1) because most of the admitted statements were not made with the primary purpose of creating a substitute for trial testimony they were non testimonial and did not violate Defendant's confrontation rights; and (2) to the extent that the victim's statements were testimonial, the only such statement was duplicative of other evidence, and its admission was harmless beyond a reasonable doubt. View "Commonwealth v. Rand" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the court denying Plaintiff's petition for relief after she was suspended without pay from her position as an assistant clerk-magistrate in the superior court following her indictment on felony charges, holding that there was no error or abuse of discretion in the denial of relief.In her petition, Plaintiff argued, among other things, that the executive office of the trial court exceeded its authority by acting pursuant to a provision of its personnel manual mandating suspension without pay of employees charged with felonies. The Supreme Judicial Court affirmed, holding (1) Plaintiff's suspension without pay upon the issuance of a federal felony indictment was consistent with and mandated by the terms of the personnel manual, the promulgation of which constituted a permissible exercise of the Court Administrator's authority; (2) the single justice did not err in finding that the trial court's procedures satisfied due process; and (3) Plaintiff was not entitled to relief on her equal protection claims. View "Moore v. Executive Office of the Trial Court" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree on the theory of felony-murder, unlawful possession of a firearm, and attempted armed robbery, holding that there was no error.Specifically, the Supreme Judicial Court held (1) counsel's failure to file a motion to suppress Defendant's text messages was not ineffective assistance of counsel because probable cause was established; (2) counsel was not ineffective for failing to exclude cell site location information; (3) Defendant was not was prejudiced by defense counsel's failure to object to in-court and out-of-court identifications made by an eyewitness; and (4) there was no other basis to set aside or reduce the verdict of murder in the first degree or to order a new trial under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Louis" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree, on a theory of felony order, with aggravated rape as the predicate felony, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Judicial Court held (1) there was sufficient evidence to prove that the homicide and the aggravated rape were parts of one continuous event; (2) if there was any error in the prosecutor's closing argument, Defendant was not prejudiced by it; (3) there was no error in the judge's Tuey-Rodriguez charge to the jury; (4) the judge's response to a jury question about the permissibility of inferences from a lack of evidence did not violate Defendant's right to due process; and (5) there was no reason to reduce the verdict or to order a new trial under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Witkowski" on Justia Law

The Supreme Judicial Court affirmed the decision of the superior court allowing Defendant's motion to suppress all of the statements he made after having invoked his right to counsel, holding that the trial judge did not err in granting the motion to suppress.Defendant was arrested on charges of murder in the first degree and possession of a firearm without a license. Although Defendant first agreed to waive his Miranda rights and speak with police in an interrogation room, twenty minutes after the interview began Defendant requested to speak with an attorney. Forty-five minutes later, Defendant again waived his Miranda rights and agreed with speak with the police. Defendant was subsequently interviewed for about one hour. Thereafter, Defendant moved to suppress all of the statements he made after having invoked his right to counsel. The superior court judge allowed the motion to suppress, concluding that it had not been established beyond a reasonable doubt that Defendant reinitiated the interview and knowingly, voluntarily, and intelligently waived his right to counsel. The Supreme Judicial Court affirmed, holding that the trial judge did not err. View "Commonwealth v. Gonzalez" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of unlawful distribution of heroin as a subsequent offender and unlawful possession of heroin with intent to distribute as a subsequent offender, holding that the superior court did not err by denying Defendant's motion to suppress and that there was no other error.In his suppression motion, Defendant sought to suppress evidence found during a warrantless search of a motor vehicle. The superior court denied the motion to suppress. The Supreme Judicial Court affirmed the denial of the suppression motion and Defendant's convictions, holding (1) the police had probable cause to search the vehicle, and there was no error in the denial of the motion to suppress; (2) the trial judge erred in allowing the admission of an in-court identification made by a police officer, but the error did not prejudice Defendant; and (3) there was no substantial risk of a miscarriage of justice as to the jury instructions on possession and distribution of narcotics. View "Commonwealth v. Ortiz" on Justia Law

In this appeal from various orders regarding Defendant's pretrial detention status the Supreme Judicial Court vacated the decision of the single justice concluding that no due process violation occurred regarding one case and ruled that the other case was moot, holding that remand was required for a determination as to whether Defendant's continued pretrial confinement violates due process.Defendant had been held in pretrial detention for more than eighteen months on charges arising out of the Chelsea Division and the Lynn Division of the District Court Department. At the time of this opinion, Defendant had been held for over a year beyond his initial trial dates. Defendant was eventually acquitted of the charges in the Chelsea case. In the Lynn case, Defendant's trial was delayed due to the COVID-19 pandemic. At issue was whether the prolonged detention violated Defendant's due process rights. The Supreme Judicial Court held (1) in analyzing whether a defendant's pretrial detention violates due process this opinion contains a procedural framework; (2) because Defendant was acquitted in the Chelsea case, that case was moot; and (3) as to the Lynn case, the matter must be remanded for further proceedings. View "Mushwaalakbar v. Commonwealth" on Justia Law

The Supreme Judicial Court vacated the decision of the superior court judge allowing Defendant's motion to suppress, holding that Defendant enjoyed no reasonable expectation of privacy in the text messages sent by him that were stored on a cellular telephone belonging to, and possessed by, another person.Defendant and six codefendants were indicted on charges of trafficking in cocaine, conspiracy to violate drug laws, and conspiracy to commit money laundering. The charges stemmed from an investigation originating, in part, from evidence acquired during a search of a codefendant's cell phone. The owner of the telephone filed a motion to suppress evidence obtained as a result of the search of his phone, including the contents of text messages sent by Defendant. Defendant moved to join the motion. The Commonwealth opposed the motion, arguing that Defendant lacked standing to challenge the search. The judge ruled that Defendant had standing and allowed him to join the motion. The Supreme Judicial Court reversed, holding that Defendant could not challenge the reasonableness of the search because he lacked a reasonable expectation of privacy in the sent text messages. View "Commonwealth v. Delgado-Rivera" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for two counts of murder in the first degree and the denial of his motion for a new trial, holding that Defendant was not deprived of his constitutional right to the effective assistance of counsel.On appeal, Defendant argued, among other things, that it was manifestly unreasonable for his trial counsel to forgo mental health defenses in favor of a third-party culprit defense. The Supreme Judicial Court disagreed, holding (1) trial counsel was not ineffective for urging one defense over the other, and Defendant was not prejudiced by his trial counsel's performance; and (2) there was no basis upon which to exercise the Court's extraordinary authority to order a new trial or to reduce the verdicts pursuant to Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Velez" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of both deliberate premeditation and extreme atrocity or cruelty, holding that there was no reversible error either in any issue raised by Defendant or in this Court's review under Mass. Gen. Laws ch. 33E.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress handwritten note and oral statements he made to officers while he was hospitalized; (2) Defendant was not entitled to reversal of his convictions on the grounds of error in the trial judge's evidentiary rulings; (3) the trial judge did not err in denying Defendant's motion for a new trial; and (4) there was no basis for reducing Defendant's sentence on the murder conviction or ordering a new trial. View "Commonwealth v. Welch" on Justia Law