Justia Massachusetts Supreme Court Opinion Summaries

The three cases before the Supreme Court here involved the validity of certain procedures adopted by the superior court to handle postconviction matters in criminal cases where a defendant was convicted of a drug offense. The drugs at issue were analyzed at the William A. Hinton State Laboratory Institute, where chemist Annie Dookhan worked on at least 34,000 cases. At the time of this opinion, Dookhan was the subject of allegations that she falsified drug testing results, tampered with evidence, and forged signatures on documents. Here special magistrates conducted hundreds of hearings, a substantial number of which pertained to Defendants' motions to stay the execution of their sentences. The Commonwealth filed petitions challenging the superior court's procedures in handling the postconviction matters. The Supreme Court answered questions reported by a single justice by holding, among other things, that in exceptional circumstances, a judge of the superior court has the authority to allow a defendant's motion to stay the execution of his sentence, then being served, pending disposition of the defendant's motion for a new trial, but a special magistrate appointed by the chief justice of the superior court does not have such authority. View "Commonwealth v. Charles" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. The Supreme Court affirmed, holding (1) the trial judge did not err in finding Defendant failed to make a prima facie case of bias regarding the prosecutor's exercise of a peremptory challenge of the only African-American male who remained in the venire; (2) the trial judge's sanctions and jury instructions crafted in response to defense counsel's violation of a reciprocal discovery order did not deny Defendant his right to a fair trial; (3) the trial judge did not err in failing to provide the jury with a Commonwealth v. DeGiambattista instruction, as Defendant was not entitled to such an instruction; and (4) the prosecutor's statements during her closing argument were not prejudicial. View "Commonwealth v. Issa" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation for the stabbing death of his wife. The Supreme Court affirmed Defendant's conviction, holding (1) portions of testimony by a substitute medical examiner violated Defendant's state and federal rights to confrontation and should not have been admitted, but the admission of the testimony did not create a substantial likelihood of a miscarriage of justice; (2) the trial judge did not abuse his discretion in denying Defendant's motion for individual voir dire of the venire with respect to each member's experience with domestic violence; and (3) the trial judge did not abuse his discretion in denying Defendant's motion to reduce the verdict to murder in the second degree. View "Commonwealth v. Reavis" on Justia Law

After a jury trial, Defendant was convicted of murder in the first degree on a theory of deliberate premeditation. The Supreme Court affirmed the convictions, holding (1) the superior court judge did not err in admitting testimony that the victim threatened to throw rocks at or otherwise destroy what he believed to be Defendant's house; (2) trial counsel's failure to request that the jury be specifically instructed on issues relating to eyewitness identification was not likely to have influenced the jury's conclusion, and therefore, did not result in a substantial likelihood of a miscarriage of justice; (3) the prosecutor made one improper statement in his closing argument that created no substantial likelihood of a miscarriage of justice; and (4) because the weight of the evidence supported the jury's verdict of murder in the first degree, the Court declined to exercise its extraordinary authority to grant relief under Mass. Gen. Laws. ch. 278, 33E. View "Commonwealth v. Franklin" on Justia Law

After Defendants were charged with Medicaid fraud, the Commonwealth obtained search warrants to obtain and search designated e-mail accounts of Defendants' former billing director. Defendants moved for a protective order, claiming that the attorney-client privilege protected many of the e-mails. A motion judge amended the order to permit the Commonwealth to search the e-mails by using a "taint team," assistant attorneys general not involved in the investigation or prosecution of Defendants. Defendants filed a petition seeking relief from the order. The Supreme Court answered reported questions from the county court by holding (1) the Commonwealth may, by means of an ex parte search warrant, search the post-indictment emails of a criminal defendant; and (2) the "taint team" procedure was permissible under the Massachusetts Constitution. View "Preventive Med. Assocs. v. Commonwealth" on Justia Law

After a second jury trial, John Irwin was convicted of indecent assault and battery on a child under fourteen. The appeals court later vacated Defendant's conviction and granted him a new trial, finding that the use of Irwin's prearrest silence as evidence of consciousness of guilty was a constitutionally impermissible comment on his privilege against self-incrimination. After the Commonwealth filed a nolle prosequi, Irwin sought compensation for an erroneous felony conviction. A superior court judge denied the Commonwealth's motion to dismiss Irwin's judgment and allowed partial judgment on the pleadings, finding that Irwin was an eligible claimant under the erroneous convictions statute. The Supreme Court reversed, holding (1) under the doctrine of present execution, an interlocutory appeal in this case was appropriate; and (2) Irwin was not eligible to pursue his compensation claim because Irwin's conviction was not overturned on grounds tending to establish his innocence, and thus, he was not an eligible claimant under the statute. Remanded. View "Irwin v. Commonwealth" on Justia Law

While in the vicinity of a college, a campus police officer, appointed as a special State police officer pursuant to Mass. Gen. Laws ch. 22C, 63, observed Defendant driving recklessly. The officer stopped Defendant's vehicle just beyond the heart of campus. Defendant was later placed under arrest and charged with operating while under the influence of alcohol, among other charges. Defendant moved to suppress the evidence, contending that the campus police officer did not have the authority to stop him beyond the boundaries of the college campus. A motion judge granted the motion, concluding that the offense and stop essentially occurred off campus and that circumstances did not permit the stop to be made in the "environs surrounding the campus." The Supreme Court reversed, holding (1) the campus police officer observed Defendant commit a criminal offense in or upon lands used by the college; (2) the traffic stop was either in or on those same lands or within the environs of the college; and (3) thus, the stop was permissible under section 63. View "Commonwealth v. Smeaton" on Justia Law

After a jury trial, Defendant was convicted of assault by means of a dangerous weapon and several firearms charges. At trial, the Commonwealth proceeded under the theory that Defendant, who did not possess the gun used in the offense, was guilty of the charged offenses as a joint venturer. The court of appeals affirmed. Defendant appealed, contending, among other things, that his firearms convictions should be reversed because the Commonwealth failed to prove beyond a reasonable doubt that his coventurer had not been issued a license to carry a loaded firearm. The Supreme Court affirmed, holding (1) where a defendant is charged with a possessory firearms offense on a theory of joint venture, the defendant must raise the defense of license before trial, and Defendant in this case failed to do so; and (2) the remainder of Defendant's claims failed. View "Commonwealth v. Humphries" on Justia Law

After a jury trial, Defendant was convicted of assault and battery by means of a dangerous weapon. Defendant appealed, contending that the trial judge erred in giving a consciousness of guilt instruction pertaining to flight where Defendant proceeded on a theory of self-defense and claimed his flight was the result of fear brought on by the circumstances. The Supreme Court affirmed, holding that the judge properly acted within her discretion in giving an instruction on consciousness of guilt over Defendant's objection, where the judge instructed the jury that Defendant could not be convicted based on consciousness of guilt alone and did not use words tending to endorse as true any inference. View "Commonwealth v. Morris" on Justia Law

After a jury trial, Defendant was convicted of rape of a child with force and indecent assault and battery of a child under fourteen. Defendant appealed, arguing, among other things, that the superior court judge erred in denying his motion to suppress evidence obtained from a warrantless search of his apartment. The Supreme Court affirmed, holding (1) under the circumstances, the police possessed sufficient factual information when they determined that a person who appeared to have authority had given consent to enter Defendant's apartment, and therefore, Defendant's Fourth Amendment rights were not violated by the warrantless entry into the home; and (2) there was no merit to Defendant's other claims of error. View "Commonwealth v. Santos" on Justia Law