Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed the judgment of a single justice of the county court denying Appellant’s petition filed pursuant to Mass. Gen. Laws ch. 211, 3, holding that retrying Appellant after his first trial ended in a mistrial will not violate his protection against double jeopardy.Appellant was charged with murder in the first degree. After deliberating for several days, the jury reported that they were deadlocked. The judge determined that the deliberating and alternate jurors had improperly communicated and thus engaged in misconduct. Appellant filed a motion for a mistrial on this basis. The judge allowed the motion. Thereafter, Appellant filed a motion to dismiss the indictment. The judge denied the motion. Appellant then filed this petition seeking review of that decision. The Supreme Judicial Court affirmed, holding that because the evidence was legally sufficient to support a murder verdict against Appellant, retrying him will not violate the guarantee against double jeopardy. View "Pinney v. Commonwealth" on Justia Law

The Supreme Judicial Court declined, in this case, to depart from the tenet that a traffic stop constitutes a reasonable seizure for purposes of article 14 of the Massachusetts Declaration of Rights where a police officer has observed a traffic violation, notwithstanding the officer’s underlying motive for conducting the stop.The Supreme Judicial Court affirmed the denial of Defendant’s motion to suppress evidence seized during a traffic stop and affirmed Defendant’s conviction of unlawful possession of a controlled substance, holding (1) the stop at issue was justified based on the law enforcement officer’s observation of the vehicle speeding; (2) a question to the driver about the smell of marijuana did not fall beyond the permissible scope of the stop; and (3) the motion judge did not err in finding that the driver freely and voluntarily consented to the search of the vehicle. View "Commonwealth v. Buckley" on Justia Law

A driver’s consent to allow law enforcement officers to search for narcotics or firearms “in the vehicle” does not authorize the officer to search under the hood of the vehicle and, as part of that search, to remove the vehicle’s air filter.The superior court in this case granted Defendant’s motion to suppress, concluding that the scope of Defendant’s consent for officers to search for narcotics or firearms "in the vehicle" was limited to a search for narcotics or firearms in the vehicle’s interior and did not include a search under the hood beneath the air filter. The Supreme Judicial Court affirmed, holding that the search exceeded the scope of Defendant’s consent, and therefore, the search of the air filter under the hood was unconstitutional. The court thus affirmed the motion judge’s order allowing Defendant’s motion to suppress the weapons found in the air filter and Defendant’s subsequent statements to the police related to his possession of those weapons. View "Commonwealth v. Ortiz" on Justia Law

A driver’s consent to allow law enforcement officers to search for narcotics or firearms “in the vehicle” does not authorize the officer to search under the hood of the vehicle and, as part of that search, to remove the vehicle’s air filter.The superior court in this case granted Defendant’s motion to suppress, concluding that the scope of Defendant’s consent for officers to search for narcotics or firearms "in the vehicle" was limited to a search for narcotics or firearms in the vehicle’s interior and did not include a search under the hood beneath the air filter. The Supreme Judicial Court affirmed, holding that the search exceeded the scope of Defendant’s consent, and therefore, the search of the air filter under the hood was unconstitutional. The court thus affirmed the motion judge’s order allowing Defendant’s motion to suppress the weapons found in the air filter and Defendant’s subsequent statements to the police related to his possession of those weapons. View "Commonwealth v. Ortiz" on Justia Law

The Supreme Judicial Court affirmed the trial judge’s denial of Defendant’s motion for a new trial on the grounds that he was denied the effective assistance of counsel during his criminal trial. Specifically, Defendant argued that his counsel provided ineffective assistance because counsel failed to furnish the judge with the expert testimony, scholarly articles, or treatises necessary to enable the judge to determine that the principles in Defendant’s proposed eyewitness identification instruction were generally accepted in the relevant scientific community. The trial judge found that counsel’s decision not to present expert testimony and other evidence was a tactical one that was not manifestly unreasonable. The Supreme Judicial Court agreed, holding that the judge neither erred nor abused his discretion in denying Defendant’s motion for a new trial. View "Commonwealth v. Gomes" on Justia Law

The Supreme Judicial Court affirmed Defendant’s convictions for murder in the first degree on the theory of deliberate premeditated and armed assault with intent to murder, affirmed the denial of Defendant’s motion for postconviction relief, and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce or set aside the verdict of murder in the first degree. The court held (1) Defendant’s constitutional right to a public trial was not violated by the trial judge’s order limiting courtroom entry only to attendees whose names were submitted and approved; (2) there was sufficient evidence to support a finding of joint venture; (3) the prosecutor did not commit misconduct in his closing argument; and (4) the trial judge did not err in instructing the jury about cooperating witnesses. View "Commonwealth v. Fernandes" on Justia Law

A sentencing judge’s consideration of victim impact statements “as to a recommended sentence” is constitutional under the Eighth Amendment to the United States Constitution and article 26 of the Massachusetts Declaration of Rights, and a victim’s right to recommend a sentence pursuant to Mass. Gen. Laws ch. 258B, 3(p) satisfies the requirements of due process.A jury convicted Defendant of assault and battery. At the sentencing hearing, the victim gave an impact statement and recommended a sentence. The judge sentenced Defendant to a lesser term of imprisonment than the sentences recommended by both the Commonwealth and the victim, explaining that in deciding the appropriate sentence, he placed great weight on the victim’s injuries and Defendant’s criminal record. On appeal, Defendant challenged the portion of Mass. Gen. Laws ch. 258B, 3(p) that permits victims to provide an impact statement “as to a recommended sentence.” The Supreme Judicial Court affirmed, holding that “it is neither cruel nor unusual or irrational, nor is it violative of a defendant’s due process guarantees, for a judge to listen with intensity to the perspective of a crime victim.” View "Commonwealth v. McGonagle" on Justia Law

The Supreme Judicial Court affirmed the decision of the district court judge denying Defendant’s motion to withdraw his guilty pleas, holding that the motion judge correctly determined that Defendant did not satisfy the prejudice requirement of the test set forth in Commonwealth v. Saferian, 366 Mass. 89 (1974). As grounds for his motion, Defendant argued that plea counsel was constitutionally ineffective for failing to advise him of the duty to register as a sex offender, and its consequences, or explain that Defendant might have sought a continuance without a finding. The district court found Defendant’s affidavit and assertions not credible and denied the motion. The Supreme Court affirmed, holding that Defendant failed to satisfy the second prong of the Saferian standard and thus could not prevail on an ineffective assistance of counsel claim. View "Commonwealth v. Lastowski" on Justia Law

The Supreme Judicial Court affirmed the convictions of defendants Reginald Holley and Oasis Pritchett for felony-murder in the first degree, armed robbery, and possession of a firearm without a license, as joint venturers, and declined to set aside the verdicts or reduce the degree of guilt pursuant to the court’s authority under Mass. Gen. Laws ch. 278, 33E. The court held (1) the evidence was sufficient to support Defendants’ convictions of felony-murder in the first degree; (2) the trial judge did not err in denying Defendants’ motion to suppress the content of their text messages; (3) the trial judge did not err in declining to instruct the jury on felony-murder in the second degree and in dismissing an ill juror during the jury’s deliberations; (4) the judge did not err by denying Pritchett’s motion to sever Defendants’ trials; and (5) the judge did not err in admitting evidence of prior bad acts and declining to instruct the jury on the requirements of the hearsay exemption concerning joint venturer statements. View "Commonwealth v. Holley" on Justia Law

The Supreme Judicial Court affirmed the conviction of Defendant for murder in the first degree on a theory of deliberate premeditation and declined to grant extraordinary relief pursuant to Mass. Gen. Laws ch. 278, 33E. Specifically, the Supreme Judicial Court held (1) the presence of investigating police officers in the grand jury room during witness testimony in support of the indictments against Defendant did not result in structural error requiring the reversal of Defendant’s convictions; (2) Defendant did not receive ineffective assistance of counsel during trial, nor was there prosecutorial misconduct; and (3) the admission of statements Defendant made during an interview with police did not violate his Miranda rights. View "Commonwealth v. Woollam" on Justia Law