Justia Massachusetts Supreme Court Opinion Summaries

The two defendants in this case were both convicted of criminal harassment for posting information about the victims online along with false statements about items that the victims allegedly had for sale or were giving away solely for the purpose of encouraging unwitting third parties to repeatedly contact and harass the victims, and for sending hostile communications to the victims. On appeal, Defendants challenged the constitutionality of the criminal harassment statute, both facial and as applied to them. The Supreme Judicial Court affirmed, holding (1) the criminal harassment statute is neither unconstitutionally overbroad nor vague; (2) Defendants’ as-applied constitutional challenge failed because the conduct in question was not protected speech but, rather, a hybrid of conduct and speech integral to the commission of a crime; and (3) Defendants’ remaining claims similarly failed. View "Commonwealth v. Johnson" on Justia Law

In 2011, in response to an increased number of foreclosures, the City of Springfield enacted two ordinances addressing properties left vacant during or after the foreclosure process. The mediation ordinance established a program requiring mandatory mediation between mortgagors and mortgagees. The foreclosure ordinance required owners of buildings that are vacant or undergoing foreclosure to register with the City. Six banks holding mortgage notes on properties in the City (Plaintiffs) filed suit seeking declaratory and injunctive relief from the enforcement of the ordinances. The federal district court allowed the City’s motion for summary judgment. Plaintiffs appealed, and the First Circuit certified two questions to the Supreme Judicial Court. The Court answered (1) the foreclosure statute preempts the mediation ordinance in whole but does not preempt the foreclosure ordinance; (2) the foreclosure ordinance is preempted by the Massachusetts Oil and Hazardous Material Release Prevention Act and the state sanitary code; and (3) the foreclosure ordinance does not impose an unlawful tax in violation of the Constitution of the Commonwealth of Massachusetts. View "Easthampton Savings Bank v. City of Springfield" on Justia Law

Defendant was convicted on seventeen indictments, including three counts of aggravated burglary. Two of those counts arose from the burglary of a dwelling in Agawam involving two assaults therein, and the third count arose from a break into a home in Springfield and an assault on one of its residents. Defendant filed a motion for postconviction relief seeking to correct illegal sentences, arguing (1) the two Agawan indictments were duplicative, and (2) an amendment to the Springfield indictment as to the person assaulted rendered that conviction unconstitutional. The Supreme Judicial Court reversed in part and affirmed in part, holding (1) Mass. Gen. Laws ch. 266, 14 permits only one burglary conviction per dwelling, and therefore, Defendant’s conviction on the duplicative indictment must be vacated; and (2) the name of the person assaulted was not an essential element to the crime charged in this case, and therefore, the conviction on the amended Springfield indictment was constitutional. View "Commonwealth v. Bolden" on Justia Law

After a jury trial, Defendant was convicted of murder in the second degree and other crimes. The trial judge denied Defendant’s motion for a new trial. The Supreme Judicial Court affirmed, holding (1) Defendant was not denied the effective assistance of counsel because of his attorney’s failure to object to the in-court identification of Defendant by an eyewitness and because of his attorney’s failure to object to the enforcement of a sequestration order during jury selection; (2) the trial judge did not err in denying Defendant’s motion for a new trial on the basis of prosecutorial misconduct; (3) the trial judge did not err in admitting cellular telephone records where the records were obtained by court order rather than with a search warrant; and (4) Defendant’s constitutional rights were not violated by his conviction of possession of an unlicensed firearm where Commonwealth didn’t prove that Defendant lacked a license to carry firearms. View "Commonwealth v. Collins" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on the theory of extreme atrocity or cruelty. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) the trial court did not commit prejudicial evidentiary errors undermining Defendant’s right to present his defenses and depriving him of due process and fundamental fairness under the United States Constitution and Massachusetts Declaration of Rights; (2) an isolated misstatement by defense counsel during closing arguments did not create a substantial likelihood of a miscarriage of justice; and (3) the judge improperly responded to a question posed by the jury, but the response did not prejudice Defendant. View "Commonwealth v. Cassidy" on Justia Law

After a jury trial, Appellant was convicted of murder in the first degree. The Supreme Judicial Court affirmed the conviction. Appellant later filed a motion for a new trial, alleging that his trial counsel provided ineffective assistance by failing to impeach a witness as to one of his statements and that he was deprived of counsel when his trial counsel’s law partner stood in during jury deliberations. The motion was denied without a hearing. The Supreme Judicial Court affirmed, holding (1) trial counsel did not render ineffective assistance in failing to impeach a witness as to one of his statements or in allowing her partner to stand in for her during jury deliberations; and (2) any error in permitting substitute counsel to stand in for trial counsel was not structural warranting a new trial absent a showing of prejudice. View "Commonwealth v. Valentin" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree. Defendant appealed, arguing that the trial court erred in denying his motion to suppress a surreptitiously recorded oral conversation between him and a police informant, that evidence of the conversation should have been excluded at trial, and therefore, that his conviction must be reversed. At issue before the Supreme Court was whether the one-party consent exception to the statutory prohibition against the secret recording or oral communications applied in this case. The Supreme Court reversed Defendant’s conviction, holding that the recorded conversation did not fit within the exception, that the conversation should not have been admitted in evidence at trial, and that the error was not harmless. View "Commonwealth v. Burgos" on Justia Law

After a jury trial, Defendant was convicted of deliberately premeditated murder and possession of a class B substance. The Supreme Judicial Court affirmed Defendant’s convictions, holding (1) there was no error in the denial of Defendant’s motion for a required finding of not guilty, as the evidence was sufficient to support a conviction of deliberately premeditated murder; (2) the trial court did not err in Defendant’s motion to dismiss based on Mass. R. Crim. P. 36, as amended, for the alleged denial of Defendant’s right to a speedy trial; (3) there was no error in the denial of Defendant’s motion to dismiss for belated discovery disclosure; (4) the trial judge did not err in failing to declare, sua sponte, a mistrial based on alleged jury tampering; and (5) there was no error in the judge’s instruction concerning the manner in which the jury should consider the testimony of a cooperating witness. View "Commonwealth v. Roman" on Justia Law

After a jury trial, Defendant was found guilty of six counts of possessing child pornography. Each count was premised on one or two distinct photographs culled at the same time from a single cache on Defendant’s computer. Defendant appealed, arguing that his convictions were duplicative. The Supreme Judicial Court vacated the convictions and remanded for a new trial, holding (1) where offending photographs come from a single cache and the defendant is charged with possessing them at the same point in time, the proper unit of prosecution for the possession of child pornography is only a single unit of prosecution; and (2) accordingly, the entry of six separate convictions and sentences constituted multiple punishments for the same offense in violation of the guaranty against double jeopardy. View "Commonwealth v. Rollins" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree on theories of extreme atrocity or cruelty and felony-murder, based on the underlying felonies of home invasion and armed or assaultive burglary, and five related offenses. The jury did not specify whether they found Defendant guilty of the offenses as a principal or as a joint venturer. The Supreme Judicial Court affirmed, holding (1) the evidence was sufficient to establish that Defendant shared the intent required to support his convictions; (2) there was no abuse of discretion in the manner in which the judge limited the scope of the cross-examination and the redirect examination of one of the Commonwealth’s witnesses; (3) the trial judge did not err in denying Defendant’s request for an instruction on murder in the second degree based on an uncharged offense or an instruction on intervening cause; and (4) counsel was not ineffective for failing to object when the judge instructed that accident was not a defense to the killing. View "Commonwealth v. Garcia" on Justia Law