Justia Massachusetts Supreme Court Opinion Summaries

The Supreme Judicial Court reversed the order of the trial denying Defendant's motion to vacate global positioning system (GPS) monitoring as a condition of his probation, holding that the Commonwealth failed to establish how the imposition of GPS monitoring would further its interest in enforcing the court-ordered exclusion zone surrounding the victim's home.Defendant was convicted on two indictments charging him with rape and sentenced to a term of incarceration followed by probation. As a condition of probation, the judge ordered Defendant to submit to GPS monitoring pursuant to Mass. Gen. Laws ch. 265, 47. Defendant moved to vacate the condition of GPS monitoring on the ground that it constituted an unreasonable search. The trial judge denied the motion. The Supreme Judicial Court reversed, holding that the Commonwealth did not meet its burden of establishing the constitutionality of the warrantless search. View "Commonwealth v. Roderick" on Justia Law

The Supreme Judicial Court entered judgment in favor of the Secretary of the Commonwealth on all claims in Plaintiffs' complaint raising facial constitutional challenges to various aspects of the "Act fostering voter opportunities, trust, equity and security" (VOTES Act), including claims that universal early voting provisions were facially unconstitutional, and denied Plaintiffs' request for injunctive relief, holding that there was no merit to Plaintiffs' claims.The VOTES Act, which was passed by the legislature on June 16, 2022 and approved by the Governor six days later, provided that any qualified voter in Massachusetts can vote early, in person or by mail, in primaries and biennial State elections. Plaintiffs, all associated with the Massachusetts Republican Party, brought this action challenging the VOTES Act, specifically the Act's requirement that the Secretary mail applications for early voting ballots to all registered voters by July 23, 2022. The court entered judgment for the Secretary on all claims, arguing that Plaintiffs' claim that the universal early voting provisions were facially unconstitutional was without merit and that Plaintiffs were not entitled to relief on their remaining claims. View "Lyons v. Secretary of Commonwealth" on Justia Law

The Supreme Judicial Court vacated the order of the trial court denying Defendant's motion for a new trial, holding that Defendant received constitutionally ineffective assistance of counsel during trial and that remand to the superior court was required for Defendant to receive a new trial.After a jury trial, Defendant was convicted of murder in the first degree and firearm offenses. During the trial, defense counsel disclosed confidential information to the Commonwealth regarding the location of "key incriminating evidence." Defendant filed a motion for a new trial, alleging that he had received constitutionally ineffective assistance of counsel because he had not given his counsel his informed consent to disclose the information. The superior court denied the motion. The Supreme Judicial Court vacated the superior court's judgment, holding (1) because defense counsel did not present Defendant with any other option than disclosing the existence of the incriminating evidence Defendant's purported consent to the disclosure was neither adequately informed nor voluntary; and (2) because trial counsel mistakenly believed he had a duty to disclose the incriminating evidence and did not obtain Defendant's prior consent to making that disclosure, an actual conflict of interest existed rendering the representation constitutionally ineffective. View "Commonwealth v. Tate" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions of murder in the first degree and unlawful possession of a firearm, holding that Defendant's arguments on appeal were without merit.Specifically, the Supreme Judicial Court held (1) there was no abuse of discretion in the trial judge's determination that the defense had not established a prima facie case of racial discrimination in jury selection; (2) there was no prejudicial error in the jury instructions; (3) the judge did not abuse her discretion in excusing a juror based on decades-old charges; (4) the prosecutor did not commit misconduct in this case; and (5) there was no error or other reason warranting relief under Mass. Gen. Laws ch. 278, 33E. View "Commonwealth v. Grier" on Justia Law

The Supreme Judicial Court reversed the decision of the trial court convicting Defendant of operating a motor vehicle while under the influence of alcohol (OUI) and negligent operation of a motor vehicle, holding that the trial court erred in denying Defendant's motion to suppress.Defendant moved to suppress the results of a blood alcohol content (BAC) analysis conducted by a crime lab after the police obtained and executed a search warrant for Defendant's blood, arguing that he did not consent to having his blood tested. The trial judge denied the motion. The Supreme Judicial Court reversed, holding that, in a prosecution under 24(1)(a), where the Commonwealth wishes to have admitted BAC evidence arising from testing or analysis of a defendant's blood done "by or at the direction of" police, police must first obtain the defendant's consent to the "chemical test or analysis" of his blood that may result from such evidence, regardless of whomever first drew the blood. View "Commonwealth v. Moreau" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice of the court denying Appellants' petitions for relief in the county court pursuant to Mass. Gen. Laws ch. 211, 3 from the order of the municipal court that Appellants be detained on the ground of dangerousness, holding that there was no error. Appellants were charged with unlicensed firearm possession pursuant to Mass. Gen. Laws ch. 269, 10(a) and held before trial on the ground of dangerousness. On appeal, Appellants argued that including unlicensed firearm possession as a predicate offense violates substantive and procedural due process and that there was insufficient evidence of their dangerousness. The Supreme Judicial Court disagreed, holding (1) unlicensed possession of a firearm is a constitutional predicate offense under Mass. Gen. Laws ch. 276, 58A(1); and (2) there was no abuse of discretion in the determinations that Appellants should be held on the ground of dangerousness. View "Vega v. Commonwealth" on Justia Law

The Supreme Judicial Court vacated the opinion of a panel of the appeals court affirming the probation violation hearing judge's ruling that Probationer had violated the terms of his probation by committing new crimes, revoking his probation, and sentencing him to a term of incarceration, holding that Probationer's inability to question his accuser violated his right to present a defense.The hearing justice revoked Probationer's probation on the basis of hearsay statements by the complainant, his former fiancee, who alleged that Probationer had repeatedly raped her over a period of four months when they were living together. On appeal, Probationer argued that his constitutional due process rights were violated because the complainant did not appear at the hearing to testify or to be cross-examined. The Supreme Judicial Court agreed, holding that precluding Probationer from calling the accuser as a witness at the hearing violated Probationer's due process right to present a defense. View "Commonwealth v. Costa" on Justia Law

The Supreme Judicial Court affirmed the order of a judge of the superior court granting Defendant's motion to suppress evidence of a firearm discovered during what Defendant alleged was an unlawful patfrisk, holding that the motion to suppress was properly granted.The Commonwealth filed an interlocutory appeal challenging the grant of Defendant's motion to suppress, arguing that the officers' suspicion that Defendant was armed and dangerous was reasonable. The Supreme Judicial Court disagreed, holding (1) the motion judge properly found that Defendant's behavior did not create reasonable suspicion that he was armed and dangerous; and (2) Defendant's reactions to the traffic stop did not justify the subsequent patfrisk. View "Commonwealth v. Garner" on Justia Law

The Supreme Judicial Court remanded this matter to the county court for entry of a judgment declaring that the Attorney General's summary and the Secretary's one-statement statements regarding a legislative amendment were in compliance with the requirements of article 48 of the Amendments to the Massachusetts Constitution, as amended by article 74 of the Amendments.At issue in this case was a legislative amendment that would impose a tax on a portion of annual incomes of $1 million, to be used, subject to appropriation by the legislature, for education and transportation purposes. In preparing to submit the amendment to voters the Attorney General and the Secretary of the Commonwealth prepared informational materials to be distributed across the Commonwealth. Plaintiffs argued that some of the materials were constitutionally and statutorily defective. The Supreme Judicial Court disagreed and affirmed, holding (1) the Attorney General's summary was in compliance with the requirements of article 48, as amended by article 74; and (2) the Attorney General and Secretary's one-sentence statements describing the effects of a "yes" vote and a "no" vote are in compliance with the requirements of Mass. Gen. Laws ch. 54, 53. View "Anderson v. Attorney General" on Justia Law

The Supreme Judicial Court held that the Attorney General's certification of Initiative Petition 21-13 to be placed on the ballot in the 2022 statewide election complied with article 48 of the Amendments to the Massachusetts Constitution.On September 1, 2021, the Attorney General certified to the Secretary of the Commonwealth that the initiative petition at issue, entitled "Initiative Petition for a Law to Implement Medical Loss Ratios for Dental Benefit Plans," was in proper form for submission to the people. After it was determined that a sufficient number of certified signatures had been submitted Plaintiffs brought this action alleging that the measure was not in compliance with the requirement that an initiative petition contain only subjects that are related or that are mutually dependent. The Supreme Judicial Court denied relief, holding that Initiative Petition 21-13 did not contain unrelated subjects and that the Attorney General's certification complied with article 48. View "Clark v. Attorney General" on Justia Law