Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree and declined to exercise its extraordinary power to set aside or reduce the verdict under Mass. Gen. Laws ch. 278, 33E, holding that Defendant’s claims of ineffective assistance of counsel failed and that the trial judge did not commit reversible error in her rulings.Specifically, the Court held (1) the trial judge did not err in admitting portions of a recorded police interview; (2) the trial judge properly admitted testimony regarding an argument a witness had with the victim; (3) the judge did not err in disallowing defense counsel’s line of questioning to a witness; and (4) Defendant did not receive ineffective assistance of trial counsel during the proceedings below. View "Commonwealth v. Cruzado" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree on the theories of premeditation and extreme atrocity or cruelty and other crimes and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E, holding that none of Defendant’s assignments of error warranted reversal.Specifically, the Court held (1) the motion judge did not err in denying Defendant’s motion to suppress statements he made to a psychiatrist in the presence of police officers guarding him at the hospital; (2) the trial judge did not err in instructing the jury regarding the presumption of sanity, the consequences of finding Defendant not guilty by reason of insanity, the failure to take prescribed medications, and reasonable doubt; and (3) the trial court did not err in denying Defendant’s request for a jury-waived trial pursuant to Mass. Gen. Laws ch. 263, 6. View "Commonwealth v. Waweru" on Justia Law

The Supreme Judicial Court held that, by failing to raise a timely objection to an improper courtroom closure at trial, a defendant forfeits or procedurally waives his or her entitlement to the standard of review designated for meritorious and preserved claims of structural error, even if counsel and Defendant were subjectively unaware that the courtroom had been closed at trial.The motion judge granted Defendant’s motion for a new trial, concluding that because Defendant and his counsel were unaware that the courtroom had been closing during empanelment, counsel’s failure to contemporaneously object to the close did not constitute a procedural waiver of his claim that he was denied his Sixth Amendment right to a public trial. The Supreme Judicial Court reversed, holding (1) Defendant’s claim was procedurally waived despite the fact that he and his counsel were factually unaware of the courtroom closure when it occurred at trial; and (2) where a procedurally-waived Sixth Amendment public trial claim is raised in a motion for a new trial, a reviewing court analyzes the purported error to determine whether the error created a substantial risk of a miscarriage of justice. The court remanded the case for review of Defendant’s claim under the appropriate standard. View "Commonwealth v. Robinson" on Justia Law

The twenty-day blackout period for voter registration prior to an election does not violate the Massachusetts Constitution.The trial judge in this case declared Mass. Gen. Laws ch. 51, 1, 1F, 26 and 34 to be unconstitutional to the extent that these statutes’ twenty-day deadline operates to deny constitutionally qualified voters the right to cast a ballot. The Supreme Judicial court vacated the judgment of the superior court and remanded the case, holding that the twenty-day deadline was not unconstitutional but that the Legislature has a continuing duty to ensure that the deadline is no further from election day than what the Legislature reasonably believes is consistent with the Commonwealth’s interest in conducting a fair and orderly election. View "Chelsea Collaborative, Inc. v. Secretary of the Commonwealth" on Justia Law

The Attorney General’s decisions to certify Initiative Petition 17-07 and not to certify the related petition, Initiative Petition 17-08, were correct.Initiative Petition 17-07 would limit the number of patients who may be assigned to a registered nurse in the Commonwealth’s healthcare facilities and would prohibit facilities from reducing certain other healthcare staff. Initiative Petitioner 17-08 contained the same provisions as the first petition and added a section that would require publicly funded hospitals to make annual public disclosures of their financial assets. While certifying that the first petition met the requirements of article 48 of the Amendments to the Massachusetts Constitution, the Attorney General declined to certify the second petition on the grounds that the mandate for financial disclosure was not sufficiently related to or mutually dependent upon the other provisions in the petition. The Supreme Judicial Court held that the Attorney General’s decisions to certify Initiative Petition 17-07 and not to certify Initiative Petition 17-08 were in compliance with the requirements of article 48. View "Oberlies v. Attorney General" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree on the theory of extreme atrocity or cruelty and other crimes, holding that, although certain of the prosecutor’s questions and comments concerning Defendant’s prearrest silence were improper, these errors did not create a substantial likelihood of a miscarriage of justice.The Court further held (1) there was ample evidence to support the prosecutor’s statement during closing argument that Defendant struck the victim repeatedly with a hammer; and (2) there was no error in the judge’s instructions on the lesser included offenses to murder in the first degree. View "Commonwealth v. Gardner" on Justia Law

Initiative Petition 15-17 should not have been certified by the Attorney General as “in proper form for submission to the people” because the petition did not contain only subjects “which are related or which are mutually dependent” pursuant to article 48 of the Amendments to the Massachusetts Constitution, as amended by article 74 of the Amendments.The initiative petition in this case would ask voters to decide whether to amend the existing flat tax rate mandated by the Massachusetts Constitution in order to impose a graduated tax on residents with incomes in excess of $1 million. The initiative petition provided that all revenues received from the proposed tax “shall" be earmarked for education and transportation, subject to appropriation by the legislature. Plaintiffs filed a complaint challenging the Attorney General’s certification of the initiative petition and seeking to enjoin the Secretary of the Commonwealth from placing the petition on the 2018 statewide ballot. The Supreme Judicial Court held that the petition may not be put before the people because it contained subjects that were not related. View "Anderson v. Attorney General" on Justia Law

The Supreme Judicial Court reversed the superior court judge decision allowing Defendants’ motion to suppress statements made to detectives and pills found in one of the defendant’s vehicles on the grounds that Defendants had been subject to custodial interrogation without, in one case, any Miranda warnings and, in the other case, an inadequate warning.Defendants were two individuals who had been detained in a restaurant parking lot as part of a threshold inquiry into a street-level drug transaction. The grand jury indicted Defendants of drug offenses. The superior court allowed Defendants’ motions to suppress. The Supreme Judicial Court reversed, holding that, applying the factors set out in Commonwealth v. Groome, 435 Mass. 201, 211-212 (2001), to the circumstances of this case, Defendants did not meet their burden of showing that they were in custody when they made the incriminating statements. View "Commonwealth v. Cawthron" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree and other offenses, affirmed the trial judge’s order denying Defendant’s motion for a new trial, and declined to reduce or set aside Defendant’s convictions under Mass. Gen. Laws ch. 278, 33E.During trial, the defense attorney failed to adhere to the judge’s courtroom rules, made inappropriate comments in the presence of the jury, and interrupted the judge on multiple occasions. The Supreme Judicial Court held (1) the judge’s admonishments to defense counsel were well within the judge’s authority, and the judge’s jury instructions mitigated any potential prejudice that might have resulted from the jury observing the disputes; (2) the reconstruction of a missing portion of the record was proper and adequate; (3) there was no evidentiary error; and (4) any purported error in the Commonwealth’s closing statement was not prejudicial. Further, the Court declined to exercise its section 33E power based on friction generated as a result of the judge having to rein in defense counsel’s inappropriate courtroom conduct. View "Commonwealth v. Imbert" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree and other offenses, affirmed the trial judge’s order denying Defendant’s motion for a new trial, and declined to reduce or set aside Defendant’s convictions under Mass. Gen. Laws ch. 278, 33E.During trial, the defense attorney failed to adhere to the judge’s courtroom rules, made inappropriate comments in the presence of the jury, and interrupted the judge on multiple occasions. The Supreme Judicial Court held (1) the judge’s admonishments to defense counsel were well within the judge’s authority, and the judge’s jury instructions mitigated any potential prejudice that might have resulted from the jury observing the disputes; (2) the reconstruction of a missing portion of the record was proper and adequate; (3) there was no evidentiary error; and (4) any purported error in the Commonwealth’s closing statement was not prejudicial. Further, the Court declined to exercise its section 33E power based on friction generated as a result of the judge having to rein in defense counsel’s inappropriate courtroom conduct. View "Commonwealth v. Imbert" on Justia Law