Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree and aggravated rape and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E to reduce the verdict in this case arising from a reopened investigation into a previously unsolved murder. The court held (1) challenged statements made by the prosecutor during closing argument did not create a substantial likelihood of a miscarriage of justice; and (2) because there was no error in the prosecutor’s statements during closing argument, Defendant failed in his argument that trial counsel was ineffective for failing to object to the improper statements in the prosecutor’s closing. View "Commonwealth v. Diaz" on Justia Law

The Supreme Judicial Court affirmed the denial of Defendant’s motion to exclude the results of a breathalyzer test taken by the Alcotest 7110 MK III-C at his trial for operating a motor vehicle while under the influence of alcohol.In an earlier appeal, the Supreme Judicial Court remanded this case to the district court to conduct a hearing on the scientific reliability of the Alcotest. After a hearing, the district court concluded that the Alcotest was capable for producing scientifically reliable breath test results and denied Defendant’s motion to exclude this evidence. The Supreme Judicial Court affirmed, holding that the district judge did not abuse his discretion in finding that the Alcotest satisfies the Daubert-Lanigan standard for the admissibility of scientific evidence. View "Commonwealth v. Camblin" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on a theory of deliberate premeditation and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E. On appeal, Defendant argued that his defense counsel, the trial judge, and the prosecutor all committed error, requiring a new trial. The Supreme Judicial Court held (1) any error on the part of the defense counsel did not create a substantial likelihood of a miscarriage of justice; (2) the admission of certain prior bad act evidence was error, but there was no substantial likelihood of a miscarriage of justice; (3) there was no error in the prosecutor’s remarks during closing argument; and (4) there was no error in the jury instructions. View "Commonwealth v. Vazquez" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction for murder in the first degree on a theory of deliberate premeditation and declined to exercise its extraordinary power under Mass. Gen. Laws ch. 278, 33E. On appeal, Defendant argued that his defense counsel, the trial judge, and the prosecutor all committed error, requiring a new trial. The Supreme Judicial Court held (1) any error on the part of the defense counsel did not create a substantial likelihood of a miscarriage of justice; (2) the admission of certain prior bad act evidence was error, but there was no substantial likelihood of a miscarriage of justice; (3) there was no error in the prosecutor’s remarks during closing argument; and (4) there was no error in the jury instructions. View "Commonwealth v. Vazquez" on Justia Law

The Supreme Judicial Court vacated and set aside Defendant’s conviction for murder in the first degree on the theory of felony-murder, with unarmed robbery as the predicate felony, and remanded the matter to the superior court for further proceedings, holding that Defendant’s trial counsel provided constitutionally ineffective assistance. The Supreme Judicial Court held (1) the evidence was sufficient to support Defendant’s conviction; but (2) Defendant was entitled to a new trial because his trial counsel was deficient for failing to have filed a motion to suppress the search of Defendant’s cellular telephone, and the improperly-admitted evidence likely influenced the jury’s verdict. View "Commonwealth v. Morin" on Justia Law

In this case filed by a Massachusetts-based company (“LevelUp”) against a California-based company (“Punchh”), alleging defamation and related causes of action connected with Punchh’s allegedly false statements about LevelUp to LevelUp’s prospective clients, the superior court allowed Punchh’s motion to dismiss on the grounds that it would not comport with due process to hale Punchh into a Massachusetts court. The Supreme Judicial Court remanded this matter to the superior court for further proceedings, holding (1) prior to exercising personal jurisdiction over a nonresident defendant, a judge must determine that doing so comports with both the forum’s long-arm statute and the requirements of the United States Constitution; and (2) the requisite statutory analysis did not occur in this case. View "SCVNGR, Inc. v. Punchh, Inc." on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court dismissing as moot the petition filed by the Lawyers’ Committee for Civil Rights and Economic Justice seeking declaratory and injunctive relief requiring Respondents - the court administrator, office of court management, and executive office of the trial court - to produce certain records pursuant to the public records law, Mass. Gen. Laws ch. 66, 10. The Lawyers’ Committee specifically requested that Respondents produce documents concerning the demographics of the security department of the trial court, by race and gender, and the department’s hiring and promotion practices. Respondents eventually produced the documents that were responsive to the Lawyers’ Committee’s request. The Supreme Judicial Court held that, under the circumstances, the single justice properly dismissed the petition as moot, as no further effective relief could be granted. View "Lawyers' Committee for Civil Rights and Economic Justice v. Court Administrator of the Trial Court" on Justia Law

The Supreme Judicial Court affirmed Defendant’s conviction of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty and the denial of Defendant’s motion for a new trial, holding that Defendant’s motion to suppress his confession was properly denied.Following a police interview lasting nearly five hours, Defendant confessed to having killed his mother. Defendant filed a motion to suppress his statement as involuntary. The trial court denied the motion to suppress. On appeal, Defendant argued that the waiver of his Miranda rights was involuntary, that his confession was obtained absent a valid waiver of his right to prompt arraignment, that his confession was coerced, that he was arrested without probable cause, and that his counsel was ineffective not not seeking suppression on certain grounds. The Supreme Judicial Court affirmed the conviction and declined to exercise its authority under Mass. Gen. Laws ch. 278, 33E to order a new trial or reduce the degree of guilt, holding that the trial judge committed no error warranting reversal, and there was no constitutionally ineffective assistance by trial counsel. View "Commonwealth v. Cartright" on Justia Law

The Supreme Judicial Court reversed Defendant’s convictions of involuntary manslaughter and assault and battery and remanded the case for a new trial.On appeal, Defendant argued that the trial judge committed reversible error by failing to conduct a voir dire after the prosecutor reported that some jurors fell asleep during the trial. The Supreme Judicial Court held that Defendant met his burden to show that the judge’s response to the information about the sleeping jurors was a structural error that could not be considered harmless, and therefore, Defendant’s convictions must be vacated. View "Commonwealth v. Villalobos" on Justia Law

The Supreme Judicial Court remanded this case to the superior court for a determination as to whether a search exceeded the permissible scope of a warrant authorizing a search of Defendant’s apartment for certain evidence, including a cellular telephone, drug-related records, and a distinctive article of clothing. When the warrant was executed, officers seized, among other things, a large quantity of cocaine. The superior court allowed Defendant’s motion to suppress the seized evidence, concluding that the warrant affidavit failed to establish probable cause to believe that Defendant sold cocaine or a sufficient nexus between Defendant’s alleged criminal activity and his apartment. The Supreme Judicial Court vacated the order allowing Defendant’s motion to suppress, holding that the affidavit (1) established a sufficient nexus in Defendant’s criminal transaction and his residence to permit a search for the cellular telephone used to arrange the sale of cocaine to a dealer and the sweatshirt he wore while conducting the transaction; but (2) did not provide sufficient particularized information to allow a general search of the apartment for other “drug-related” evidence. View "Commonwealth v. Perkins" on Justia Law