Justia Massachusetts Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Judicial Court affirmed the judgment of the county court denying the Commonwealth's petition filed under Mass. Gen. Laws ch. 211, 3 seeking relief from a superior court judge's denial of the Commonwealth's motion to disqualify Rosemary Scapicchio, Defendant's appellate counsel, on the ground that she had a conflict of interest, holding that the single justice did not err or abuse his discretion in denying the motion.Defendant was convicted of murder in the first degree. Later, represented by Scapicchio, Defendant filed a motion for a new trial alleging ineffective of counsel. Thereafter, Scapicchio represented Michael Barros at a hearing in an unrelated criminal case. The Commonwealth moved to disqualify Scapicchio on the grounds that her representation of both Defendant and Barros gave rise to a conflict of interest. The superior court denied the motion. The Commonwealth then filed the petition at issue. The single justice denied relief without reaching its merits. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused his discretion by denying the petition. View "Commonwealth v. Monteiro" on Justia Law

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The Supreme Judicial Court declined to address the merits of these appeals challenging the Attorney General's (AG) decision denying Plaintiffs' initiative petition that would have instituted limits on contributions to independent expenditure political action committees, holding that the appeals were moot.The AG determined that the proposed law conflicted with the Massachusetts Declaration of Rights' right of free speech and, therefore, addressed an excluded subject under article 48. Ultimately, the AG concluded that the proposed limitation on campaign contributions was precluded under United States Supreme Court precedent. Plaintiffs appealed. Thereafter, the AG offered to agree to a stipulated order, but Plaintiffs refused to agree with the order. Before the Supreme Judicial Court, the AG argued that the appeals were moot because Plaintiffs did not gather the first round of signatures set forth in article 48. The Supreme Judicial Court dismissed the cases as moot, holding that Plaintiffs failed to meet the deadline to file additional signatures with the Secretary of the Commonwealth. View "Herrmann v. Attorney General" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of unlawful possession of a firearm, holding that the did not abuse its discretion in denying Defendant's motion for discovery, and there was no error in the proceedings below warranting a new trial.Defendant's conviction arose from a police investigation into a report of a shooting in a crowded residential area and the ensuing discovery of a firearm allegedly discarded by Defendant. Before trial, Defendant filed a motion for discovery of police reports that he argued was relevant and material to the question of whether the investigation was motivated by race, in violation of his constitutional equal protection rights. The trial judge denied the motion, and Defendant was subsequently convicted. The Supreme Judicial Court affirmed, holding (1) there was no abuse of discretion in the denial of Defendant's motion for discovery; and (2) some of the prosecutor's remarks during closing argument were improper, but the remarks did not warrant a new trial. View "Commonwealth v. Cuffee" on Justia Law

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The Supreme Judicial Court affirmed the denial of Defendant's motion to suppress evidence seized from his person during a stop and pat-frisk, holding that the new standard adopted in Commonwealth v. Long, 485 Mass. 711, 724-725 (2020), is applicable in the context of police investigations such as pedestrian stops in addition motor vehicle stops.Defendant was indicted on firearm-related charges after he was stopped by police officers while walking. In his motion to suppress, Defendant argued that the stop was unconstitutional because the officers lacked reasonable suspicion and because statistical evidence proved the officers were more likely to stop Black members of the community than individuals of other races. In addressing Defendant's equal protection challenge, the lower court presumed that this Court's standard for establishing an equal protection claim under the Massachusetts Declaration of Rights, which was adopted to provide a defendant a more accessible path to pursuing an equal protection claim in the context of a motor vehicle stop, applied equally to this pedestrian stop challenge. The Supreme Judicial Court affirmed, holding (1) the new standard adopted in Long is applicable in this case; and (2) the evidence supported the trial court's determination that the officers stopped Defendant to investigate his involvement in the shooting and not because of his race. View "Commonwealth v. Robinson-Van Rader" on Justia Law

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The Supreme Judicial Court held that a closed case that ends in an acquittal, a no bill from a grand jury, or a finding of no probable cause by the court is not a record subject to a presumption of access under the First Amendment and that the Legislature clearly abrogated the common-law presumption of access with respect to these records by its plain language in Mass. Gen. Laws ch. 276, 100C.Defendant was arraigned on two counts of rape while armed with a firearm and other crimes. A jury acquitted Defendant on one count of rape while armed, assault with intent to rape, and carrying a firearm without a license and deadlocked on the remaining three counts, resulting in a mistrial. The Commonwealth ultimately filed a nolle prosequi. Defendant later brought his section 100C petition to seal his criminal record as to the counts on which he was acquitted and the courts for which the nolle prosequi was filed. A judge denied the petition. The Supreme Judicial Court remanded the case for further proceedings, holding that, regarding the counts in which the nolle prosequi was entered, the judge abused his discretion when weighing the relevant interests and factors. View "Commonwealth v. J.F." on Justia Law

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The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of two counts of murder in the first degree on the theory of premeditation as to Mark Greenlaw and Jennifer O'Connor and on the theory of extreme atrocity or cruelty as to O'Connor, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in denying Defendant's motion for a mistrial regarding the victim's fear of rape; (2) the prosecutor's statement during closing argument impermissibly appeal to the jury's sympathy, but the statement did not create a substantial likelihood of a miscarriage of justice; (3) the trial judge erred in failing to instruct the jury that it could consider voluntary ingestion of drugs in determining extreme atrocity or cruelty, but the error did not create a substantial likelihood of a miscarriage of justice; (4) the judge did not err in excusing juror number fifteen; (5) the indictment charging attempted burning of a dwelling was not defective; and (6) there was no error warranting relief under Mass. Gen. Laws ch. 278, § 33E. View "Commonwealth v. Doughty" on Justia Law

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The Supreme Judicial Court affirmed Defendant's conviction of being an accessory before the fact to kidnapping and the order denying his motion for postconviction relief, holding that Defendant was not entitled to relief on his claims of error.Defendant, a police officer, provided several specific items to James Feeney, his drug supplier, at Feeney's request, including information about the victim as well as Defendant's police badge, gun holster, and handcuffs. Feeney provided the information and items to Scott Morrison and Alfred Ricci, who convinced the victim they were at his house to complete a mandatory drug test. The pair kidnapped him, and Feeney murdered him. Defendant was convicted of being an accessory before the fact to kidnapping. The Supreme Judicial Court affirmed the convictions and the denial of Defendant's postconviction motion, holding (1) the evidence was sufficient for a jury to find beyond a reasonable doubt that Defendant shared Feeney's intent that the kidnapping take place; (2) the trial judge's instructions to the jury were without error; and (3) there was no error in the trial judge's evidentiary rulings. View "Commonwealth v. Schoener" on Justia Law

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The Supreme Judicial Court affirmed the order of the superior court denying Defendant's motion to suppress, holding that the articulable facts combined to establish reasonable suspicion that Defendant had committed armed robbery.At issue was whether information known to other investigating officers may be imputed to the officer who initiated the stop under the collective knowledge doctrine. The superior court judge denied Defendant's motion to suppress evidence obtained as a result of a stop, concluding that the officer who conducted an investigatory stop on Defendant had adequate reasonable suspicion to do so. The appeals court affirmed. The Supreme Judicial Court affirmed, holding that, with or without the imputed knowledge, the officer who stopped Defendant had reasonable suspicion to do so. View "Commonwealth v. Privette" on Justia Law

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The Supreme Judicial Court held that the single justice of the county court neither erred nor abused his discretion by denying, without a hearing, Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion by denying extraordinary relief.In 1985, Petitioner was convicted of aggravated rape and other offenses. In 2005, the Sex Offender Registration Board issued a decision ordering Petitioner to register as a level three sex offender, thereafter denying Petitioner's motion for relief from the registration requirement. In this petition, Petitioner brought, among other claims, constitutional challenges to both federal and state sex offender registration laws. The single justice denied relief. The Supreme Judicial Court affirmed, holding that the single justice did not abuse his discretion in finding that no exceptional circumstances were present in this case warranting extraordinary relief. View "Rancourt v. Attorney General" on Justia Law

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The Supreme Judicial Court reversed the judgment of the superior court against Plaintiffs and directed the court to enter a judgment declaring the "public comment policy" of the town of Southborough unconstitutional,holding that the town's public comment policy violated rights protected by articles nineteen and sixteen of the Massachusetts Declaration of Rights.At issue was the policy of the board of selectmen of Southborough that outlines the public comment portion of its meetings where town residents may address the board ("public comment policy"). Plaintiffs argued, among other claims, that the policy violated their constitutionally-protected right under article nineteen "to assemble, speak in a peaceable manner, and petition...town leaders for redress." The Supreme Judicial Court reversed the superior court's decision rejecting the argument that the town's public comment policy was unconstitutional, in violation of articles nineteen and sixteen, holding that the town's civil restraints on the content of speech at a public comment session in a public meeting were forbidden under both articles nineteen and sixteen. View "Barron v. Kolenda" on Justia Law