Justia Massachusetts Supreme Court Opinion Summaries

While being held for custodial interrogation, and without having first waived the Miranda rights of which he had been advised, defendant shook his head from side to side in response to the question, "So you don't want to speak?" At issue was whether defendant, by his conduct, had invoked the right to remain silent guaranteed under the Fifth Amendment to the United States Constitution and art. 12 of the Massachusetts Declaration of rights and, if so, whether the police sufficiently honored that right. The court concluded that, under both the Fifth Amendment and art. 12, the right to remain silent was invoked but was not "scrupulously honored" and that suppression of the subsequent incriminating statements was accordingly warranted. In so concluding, the court held that, in the prewaiver context, art. 12 did not require a suspect to invoke his right to remain silent with the utmost clarity, as required under Federal law. View "Commonwealth v. Clarke" on Justia Law

Defendant was charged with possession of a Class B substance with intent to distribute and possession of a class D substance with intent to distribute and eventually entered into a plea agreement. At issue was whether a judge had the authority under Mass. R. Crim. P. 29(a), to reduce a sentence after defendant and the Commonwealth had entered into a plea in which the Commonwealth agreed not to seek indictments against defendant on the pending charges, defendant had agreed to plead guilty to the charges and join the prosecutor's sentencing recommendation, and the judge had imposed the recommended sentence. The court concluded that where, as here, a judge acted on his own timely motion to revise or revoke a sentence, the judge had the authority to reduce a sentence where it appeared that justice may not have been done regardless whether a plea agreement included an agreed sentence recommendation. View "Commonwealth v. Rodriquez" on Justia Law

Defendant was charged in a criminal complaint with a single count of armed robbery and eventually plead guilty in the District Court to a reduced charge. At issue was whether the Commonwealth had the authority to require a judge to vacate a defendant's guilty plea where the Commonwealth made a charge concession as part of the plea agreement and the judge imposed a sentence less severe than the agreed sentence recommendation. The court concluded that the Commonwealth did not have this authority under Mass. R. Crim. P. 12, as appearing in 442 Mass. 1511, or G.L.c. 278, section 18. The court further concluded that if the guilty plea were to be vacated at the prosecution's request and over the objection of the defense, double jeopardy would bar further prosecution on that charge. View "Commonwealth v. Dean-Ganek" on Justia Law

Plaintiffs filed an appeal from a decision of the board approving a minor modification to the site assignment for an existing landfill and related processing facility pursuant to G.L.c. 30A, section 14. At issue was plaintiff's standing to seek judicial review in the Superior Court of the board's decision. The court concluded that on the record before it, plaintiffs lacked standing to seek judicial review of the board's decision in the Superior Court as persons "aggrieved" and, nevertheless, plaintiffs' substantive challenges to the decision lacked merit. View "Board of Health of Sturbridge & others v. Board of Health of Southbridge & another. " on Justia Law

Defendant was convicted on two indictments charging statutory rape of his fifteen year old niece. At issue was whether defendant, whose motion to stay the execution of his sentence was denied by a single justice of the Appeals Court, could file another motion to stay the execution of his sentence before a single justice of the Supreme Judicial Court after direct appellate review was granted. The court concluded that he could so proceed, and that the single justice could elect to consider de novo defendant's application for a stay. Because the court concluded that the single justice did not abuse his discretion in allowing defendant's motion to stay the execution of the sentence, the court affirmed the judgment. View "Polk v. Commonwealth" on Justia Law

This case involved Commonwealth Care, a state-initiated program that provided structured premium assistance for low-income Massachusetts residents. In 2009, the Legislature made certain changes to the eligibility requirements of Commonwealth Care, enacted in a two-part supplemental appropriation for fiscal year 2010. Section 31(a) of the appropriation excluded all aliens who were federally ineligible under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), 8 U.S.C. 1601-1646, from participation in Commonwealth Care. Plaintiffs were individuals who either have been terminated from Commonwealth Care or have been denied eligibility solely as a result of their alienage. The court held that section 31(a) could not pass strict scrutiny and that the discrimination against legal immigrants that its limiting language embodied violated their rights to equal protection under the Massachusetts Constitution. View "Finch & others v. Commonwealth Health Ins. Connector Auth. & others" on Justia Law

Defendant was convicted, among other things, of murder in the first degree on theories of deliberate premeditation and extreme atrocity or cruelty. Defendant subsequently appealed his convictions. The court held that the evidence was sufficient to support the murder conviction; the prosecutor did misstate certain evidence at trial but the court concluded that the error did not give rise to a substantial likelihood of miscarriage of justice; and the trial judge's instructions to the jury were not erroneous. Accordingly, the court affirmed the convictions and declined to exercise its power under G.L.c. 278, section 33E, to reduce the murder verdict or order a new trial. View "Commonwealth v. Young" on Justia Law

This matter came before the court on a reservation and report by a single justice of the court of a decision and final order of the department approving a power purchase agreement (PPA) that National Grid entered into with Cape Wind. The four parties that brought the appeal were all interveners in the department's proceeding. They claim that the PPA violated the commerce clause of the United States Constitution; the department improperly found that the PPA was cost effective and in the public interest; the contract should have been solicited through competitive bidding and subject to a cap on its size; and the department erroneously both approved a method for recovering costs from all distribution customers and required that the contract facilitate financing of a renewable energy generation source. The interveners sought reversal of the department's decision and order, and a remand to the department for further proceedings. The court reviewed the department's decision under G.L.c. 25, section 5, and gave deference to the department's expertise and experience, remanding to the county court where the single justice will affirm the department's decision. View "Alliance to Protect Nantucket Sound, Inc. v. Dept. of Public Utilities & others (No. 1)" on Justia Law

Plaintiff challenged his expulsion from Weston High School for allegedly possessing and distributing a "marijuana cookie" on school property. The court held that the judge abused his discretion where the record did not suggest that the judge either considered the proper legal standards for the allowance of a motion for a preliminary injunction or evaluated the factual circumstances relevant to plaintiff's alleged misconduct. Therefore, the order regarding plaintiff's motion for a preliminary injunction was vacated in its entirety and the matter remanded. View "Doe v. Superintendent of Schools of Weston" on Justia Law

Defendant appealed from his conviction for trafficking in over fourteen grams of cocaine. On appeal, defendant contended that the Commonwealth violated his right to confront the witnesses against him when it introduced evidence from laboratory drug tests through the testimony of a substitute analyst rather than through the analyst who performed the test. Defendant also contended that the trial judge erred in admitting certain hearsay statements and that trial counsel was constitutionally ineffective. Although much of the challenged testimony was erroneously admitted, this testimony did not create a substantial risk of a miscarriage of justice; nor was defendant denied the effective assistance of counsel. Accordingly, the court affirmed the conviction. View "Commonwealth v. Munoz" on Justia Law