Justia Massachusetts Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Commonwealth v. Castillo
Defendant was indicted for aggravated rape, indecent assault and battery, and other related offenses. The charges were based on five separate incidents involving five female victims. During the pretrial proceedings, the Commonwealth provided discovery to Defendant that included records related to medical treatment that some of the alleged victims received following the incidents. Defendant subsequently filed a motion for discovery that included the request for additional medical treatment or follow up visits any victim had pertaining to the indicted offenses. The superior court allowed the motion with respect to any follow up medical visits. The Commonwealth sought relief from that order, arguing that the order was improper because it required the Commonwealth to inquire of the alleged victims whether they sought or had follow-up treatment. The Supreme Court affirmed, concluding that the judge was only allowing Defendant's request to the extent it required the Commonwealth to provide information in its possession. View "Commonwealth v. Castillo" on Justia Law
Commonwealth v. Harris
After a jury trial, Defendant was convicted of murder in the first degree on the theory of deliberate premeditation. Defendant appealed, arguing error in the admission of evidence, the prosecutor's closing argument, and the judge's instructions to the jury. The Supreme Court affirmed, holding (1) the trial court did not palpably err in admitting a 911 recording of the victim stating three times, "I've been stabbed"; (2) the prosecutor did not improperly attempt to evoke sympathy from the jury by playing, during his closing argument, the 911 recording; and (3) the trial court did not prejudicially err in its instructions to the jury on self-defense. View "Commonwealth v. Harris" on Justia Law
Rivas v. Chelsea Hous. Auth.
Plaintiff received housing assistance through the Massachusetts rental voucher program. Plaintiff rented an apartment in Chelsea and received her voucher through the Chelsea Housing Authority. In 2009, Plaintiff received notice from the Authority that it was terminating her voucher because she did not report changes in family composition and in the family's income within thirty days of the change as required by the conditions of her voucher. After a hearing, the Authority's grievance panel upheld the termination. The Board of Commissioners affirmed, as did the superior court and appeals court. The Supreme Court reversed, holding (1) it was unlawful for the Authority to proceed to the grievance panel hearing without first offering Plaintiff the opportunity to engage in settlement negotiations; (2) the regulations Plaintiff was found to have violated were impermissibly vague; and (3) the grievance panel's factual findings were insufficient. Remanded. View "Rivas v. Chelsea Hous. Auth." on Justia Law
Commonwealth v. Scott
After a jury trial, Defendant was convicted of kidnapping, assault by means of a dangerous weapon, assault and battery causing serious bodily injury, assault and battery, and malicious destruction of property. The court of appeals affirmed. The Supreme Court reversed Defendant's conviction of assault and battery causing serious bodily injury, holding that the evidence, which consisted primarily of medical records not explained by an expert witness, was insufficient to permit a rational jury to find that the victim suffered "serious bodily injury" within the meaning of the relevant statute. Remanded for resentencing on the remaining convictions. View "Commonwealth v. Scott" on Justia Law
Commonwealth v. Morales
After a jury trial, Defendant was convicted of manslaughter. The principal question on appeal was whether, during a trial where the defendant raises a claim of self-defense and, pursuant to Commonwealth v. Adjutant, has been permitted to introduce evidence of the victim's prior violent acts on the issue of the identity of the first aggressor, the Commonwealth may introduce evidence of the defendant's prior violent acts on that same issue, to be followed by an instruction that the jury may consider the evidence of both parties' violent acts on the findings of who was the first aggressor. The Supreme Court answered yes, provided that the Commonwealth gives the defendant notice appropriately in advance of its intent to introduce such evidence and the trial judge determines that introduction of such evidence is more probative of its intended purpose than prejudicial to the defendant. In so answering, the Court affirmed the judgment of the trial court. View "Commonwealth v. Morales" on Justia Law
Jones v. Boykan
In 2003, Plaintiffs filed a complaint against a police officer and city, alleging that, in 1999, the officer entered Plaintiffs' convenience store, arrested two of the plaintiffs, and beat all of the plaintiffs. Two of the plaintiffs were acquitted of criminal charges, but, in the meantime, Plaintiffs lost their business and suffered physical and emotional injuries. More than thirteen years after the incident and after a "tortuous" procedural history, the case arrived at the Supreme Court on limited further appellate review. In Jones II, the appeals court ordered the reinstatement of a 2004 default judgment against Defendants. The Court also had before it on direct appellate review an order of the superior court that amended the 2004 default judgment to correct a clerical error and that reinstated it. The Supreme Court (1) vacated the default judgment and remanded the matter for further proceedings to assess damages, holding that, under the circumstances here, a remand was necessary; and (2) vacated the amended judgment, holding that the superior court did not have jurisdiction to entertain a motion to amend the earlier default judgment, even to correct a clerical mistake, at the time the motion judge acted in 2012. View "Jones v. Boykan" on Justia Law
Shapiro v. City of Worcester
Two sets of plaintiffs brought actions against the city of Worcester, alleging that the city was liable to them for nuisance, continuing nuisance, and continuing trespass arising from the discharge of effluent from the city's sewer system onto their properties. After the lower courts made a series of rulings in favor of the city, Plaintiffs appealed. The Supreme Court held (1) Plaintiffs' nuisance claims were not barred because they failed to satisfy the presentment requirement of the Massachusetts Tort Claims Act, as application of the presentment requirement in these cases would be egregiously unfair to Plaintiffs given that the law did not require presentment of nuisance claims at the time they filed their lawsuits; and (2) none of the statutory exceptions to sovereign immunity by the city was applicable in this case, and the city remained subject to suit. Remanded. View "Shapiro v. City of Worcester" on Justia Law
Commonwealth v. Yardley Y.
In 1995, Defendant was charged with assault and battery by means of a dangerous weapon and indecent assault and battery on a child under the age of fourteen. At the time, Defendant was a minor and primarily spoke Khmai. During his plea colloquy, Defendant admitted to sufficient facts and was placed on probation. Defendant was committed to the Department of Youth Services after he violated the terms of his probation. In 2009, as an adult, Defendant sought to vacate his pleas, asserting he did not knowingly and voluntarily admit to sufficient facts where no interpreter was present during his plea colloquy and where he was denied effective assistance of counsel. The juvenile court denied Defendant's motion for a new trial, and the appeals court affirmed. The Supreme Court affirmed, holding that Defendant did not provide sufficient evidence to rebut the presumption of regularity of his plea proceedings and did not demonstrate he was denied the effective assistance of counsel. View "Commonwealth v. Yardley Y." on Justia Law
Commonwealth v. Reyes
Defendant had a license permitting him to carry a firearm for all lawful purposes. After driving to work one day, Defendant attempted to obtain a gun locker key for the storage of his firearm during his work shift, but all the lockers were full. Consequently, Defendant placed his gun in his vehicle's glove box and locked the vehicle. Defendant's car was later searched, and Defendant was charged with firearms violations. After a jury trial, Defendant was convicted of improperly carrying a firearm in a motor vehicle in violation of the carrying statute and unlawfully storing a firearm in violation of the storage statute. The Supreme Court reversed, holding (1) the evidence was insufficient to support Defendant's conviction under the carrying statute, and Defendant was entitled to a directed verdict of not guilty on that charge; and (2) because the trial judge did not properly instruct the jury regarding what qualifies as a locked container, Defendant's conviction under the storage statute was reversed and the case remanded for a new trial on that charge. View "Commonwealth v. Reyes" on Justia Law
Commonwealth v. McGowan
Defendant had a valid license to carry a firearm in Massachusetts. Defendant owned a semiautomatic handgun, which he kept loaded and unlocked in a bedroom drawer in his home. Defendant was charged with violating Mass. Gen. Laws ch. 149, 131L(a), which makes it unlawful to store a firearm not under the immediate control of the authorized user unless the firearm is secured in a locked container or equipped with a safety device that renders the firearm inoperable by anyone other than the authorized user. Defendant moved to dismiss the complaint, alleging that the statute was unconstitutional. The Supreme Court held (1) section 131L(a) is subject only to a rational basis analysis; (2) the statute is constitutional under the U.S. Supreme Court's holding in District of Columbia v. Heller and McDonald v. Chicago; and (3) Massachusetts may enforce section 131L(a) to protect the health, safety, and welfare of its citizens. View "Commonwealth v. McGowan" on Justia Law