Justia Massachusetts Supreme Court Opinion Summaries

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

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

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

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

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

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

The Supreme Judicial Court held that Mass. Gen. Laws ch. 85, 17A, sometimes referred to as the panhandling statute, is unconstitutional on its face under the First Amendment to the federal constitution and article 16 of the Massachusetts Declaration of Rights, as amended, because the statute is a content-based regulation of protected speech in a public forum that cannot withstand strict scrutiny.Under the statute, a person who signals, stops, or accosts a motor vehicle or its occupants on a public way if undertaken for the purpose of panhandling, is subject to criminal prosecution or a fine. The statute, however, exempts the same conduct if undertaken for the purpose of selling newspapers or raising money for a nonprofit organization. Plaintiffs commenced this action asserting that the statute is unconstitutional on its face under the First Amendment and article 16. The Supreme Judicial Court held that Mass. Gen. Laws ch. 85, 17A is unconstitutional on its face under the First Amendment and article 16 because it is both over- and underinclusive with respect to the purpose it is intended to serve, is not narrowly tailored, and cannot withstand strict scrutiny. View "Massachusetts Coalition for Homeless v. City of Fall River" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of three counts of murder in the first degree, one count of armed assault with intent to murder, and unlawful possession of a firearm and declined to order a new trial or reduce the degrees of guilt under Mass. Gen. Laws ch. 278, 33E, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Judicial Court held (1) the judge did not abuse his discretion in admitting prior bad act evidence or in allowing the substantive use of prior inconsistent grand jury testimony by one trial witness; (2) there was no substantial likelihood of a miscarriage of justice from trial counsel's decision not to attempt to impeach one witness with his prior grand jury testimony; and (3) impermissible comments made by the prosecutor during cross-examination of Defendant did not create a substantial likelihood of a miscarriage of justice or constitute impermissible burden shifting. View "Commonwealth v. Pierre" on Justia Law

The Supreme Judicial Court held that the Civil Defense Act (CDA), Mass. Gen. Laws ch. 17, 2A, provided the Governor with the authority for his March 10, 2020 declaration of a state of emergency in response to the COVID-19 pandemic and for his issuance of the emergency orders and that the emergency orders did not violate article 30 of the Massachusetts Declaration of Rights or Plaintiffs' federal or state constitutional rights to procedural and substantive due process or free assembly.Plaintiffs brought this complaint seeking declaratory judgment and injunctive relief, challenging the Governor's declaration of a state of emergency and the emergency orders placing restrictions on daily activities as unauthorized and unconstitutional. The Supreme Judicial Court denied relief, holding that Plaintiffs' claims were unavailing and that the emergency orders were authorized and constitutional. View "Desrosiers v. The Governor" on Justia Law

The Supreme Court affirmed the judgment of the single justice denying Defendant's petition filed pursuant to Mass. Gen. Laws ch. 211, 3 seeking to remove the conditions of GPS monitoring and home confinement on Defendant's release, holding that the conditions were constitutional.Defendant was convicted of trafficking narcotics. Defendant filed a motion for a new trial and sought to stay the execution of her sentence while her motion was pending. The trial judge granted the stay and imposed the conditions of release at issue. Defendant then filed a petition in the county court seeking relief from the conditions. The single justice denied relief. The Supreme Judicial Court affirmed, holding (1) the condition of home confinement was not a seizure because it was imposed pursuant to a valid conviction and lawful sentence; and (2) the imposition of GPS monitoring was a search, but it was reasonable under the circumstances. View "Garcia v. Commonwealth" on Justia Law